4,166 research outputs found

    Spent-beam refocusing analysis and multistage depressed collector design for a 75-W, 59- to 64-GHz coupled-cavity traveling-wave tube

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    A computational design technique for coupled-cavity tubes (TWTs) equipped with spent-beam refocusers (SBRs) and multistage depressed collectors (MDCs) is described. A large-signal multidimensional computer program was used to analyze the TWT-SBR performance and to generate the spent-beam models used for MDC design. The results of a design involving a 75-W, 59 to 64 GHz TWT are presented. The SBR and MDC designs are shown, and the computed TWT, SBR, and MDC performances are described. Collector efficiencies in excess of 94 percent led to projected overall TWT efficiencies in the 40-percent range

    Reconceptualising Australia’s transfer pricing rules: An approach based on adopting economic presence as a basis for taxation

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    Against the background of a global focus on base erosion and profit shifting and well-publicised cases of high profile multinationals minimising their taxable burden in high tax jurisdictions, including the use of transfer pricing as a major tax minimisation strategy, this paper argues for a reconceptualisation of Australia’s Transfer Pricing rules by adopting an approach based on using economic presence as a basis for source based taxation.The approach of the paper is to first discuss and evaluate the evolution of Australia’s transfer pricing legislation. In this part, it will be argued that the most current reforms to Australia’s transfer pricing regime present several fundamental deficiencies. In response to these deficiencies, the second part of the paper advocates a policy response focused on a reconceptualised version of current source rules applying economic presence as a foundation for taxation

    Opportunities for reducing farm machinery costs in the Ozarks of eastern Missouri

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    Missouri Agricultural Experiment Station and Farm Economics Research Division, Agricultural Research Service, U.S. Department of Agriculture cooperating.Digitized 2007 AES.Includes bibliographical references

    Comparative Analysis of Systems of Domestic Taxation of Controlled Foreign Corporations

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    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

    Assessment and Intervention Strategies for Test Anxiety in Aviation Students

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    Observations from faculty and anecdotal reports from students in the Aviation Department at Central Washington University (CWU) indicate that the pressures associated with stage checks, end-of course exams, and other performance thresholds required for training under Title 14 Code of Federal Regulations Part 141 (1978) appear to contribute to high levels of test anxiety (TA) and poor performance by some students. The purpose of this review is to identify assessments used for early recognition of at-risk students, review methods used to reduce test anxiety, and recommend appropriate actions for implementation of assessments and reduction strategies that can benefit aviation students attending CWU and other collegiate aviation programs engaged in professional pilot training

    Can Associations Have Priority over Fannie or Freddie?

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    An association’s six-month lien priority is sometimes termed a “superlien,” but there is nothing particularly “super” about it; the statute simply provides that an association has a lien with priority over the first mortgage, much like the lien of property taxes in nearly all states. An association’s total lien is effectively split into two components: a lien before the first mortgage for six months of assessments and a lien junior to the first mortgage for any delinquent assessment amount over six months’ worth. In this way, section 3-116 was intended to strike “an equitable balance between the need to enforce collection of unpaid assessments and the obvious necessity for protecting the priority of the security interests of lenders.” This careful balance is in jeopardy, however, as the result of challenges from the Federal Housing Finance Authority (FHFA), claiming that associations cannot foreclose on assessment liens without the FHFA’s consent if the property is subject to mortgages held by Fannie Mae or Freddie Mac. After explaining the basis for the FHFA’s novel defense, this article gives several reasons why courts should reject the defense

    VFR Flight Into IMC: Reducing the Hazard

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    Aircraft accidents resulting from initiating or continuing visual flight rules (VFR) flight into instrument meteorological conditions (IMC) continue to be one of the leading causes of fatal aircraft accidents. This paper outlines the nature and scope of this hazard and reviews past and present initiatives designed to reduce it. It also suggests future interventions that may be effective in reducing the threat of this aviation hazard

    The New Model Negotiated Alternative to the Foreclosure Act

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    One of the many painful lessons learned from the mortgage crisis that began in 2007 is that foreclosure is often a costly, slow, inefficient, and uncertain process. The additional cost and uncertainty for lenders are magnified when the balance of the mortgage debt exceeds the value of the collateral (that is, when the borrower is “underwater”), and thus full recovery by the lender of its investment is unlikely. Ways to avoid this misery are for the lender (usually represented by the servicer for a secondary market purchaser or a securitized trust) and the borrower to enter into a deed in lieu of foreclosure or for the lender to approve a short sale

    Reconfigurable, Bi-Directional Flexfet Level Shifter for Low-Power, Rad-Hard Integration

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    Two prototype Reconfigurable, Bi-directional Flexfet Level Shifters (ReBiLS) have been developed, where one version is a stand-alone component designed to interface between external low voltage and high voltage, and the other version is an embedded integrated circuit (IC) for interface between internal low-voltage logic and external high-voltage components. Targeting stand-alone and embedded circuits separately allows optimization for these distinct applications. Both ReBiLS designs use the commercially available 180-nm Flex fet Independently Double-Gated (IDG) SOI CMOS (silicon on insulator, complementary metal oxide semiconductor) technology. Embedded ReBiLS circuits were integrated with a Reed-Solomon (RS) encoder using CMOS Ultra-Low-Power Radiation Tolerant (CULPRiT) double-gated digital logic circuits. The scope of the project includes: creation of a new high-voltage process, development of ReBiLS circuit designs, and adjustment of the designs to maximize performance through simulation, layout, and manufacture of prototypes. The primary technical objectives were to develop a high-voltage, thick oxide option for the 180-nm Flexfet process, and to develop a stand-alone ReBiLS IC with two 8-channel I/O busses, 1.8 2.5 I/O on the low-voltage pins, 5.0-V-tolerant input and 3.3-V output I/O on the high-voltage pins, and 100-MHz minimum operation with 10-pF external loads. Another objective was to develop an embedded, rad-hard ReBiLS I/O cell with 0.5-V low-voltage operation for interface with core logic, 5.0-V-tolerant input and 3.3-V output I/O pins, and 100-MHz minimum operation with 10- pF external loads. A third objective was to develop a 0.5- V Reed-Solomon Encoder with embedded ReBilS I/O: Transfer the existing CULPRiT RS encoder from a 0.35-micron bulk-CMOS process to the ASI 180-nm Flexfet, rad-hard SOI Process. 0.5-V low-voltage core logic. 5.0-V-tolerant input and 3.3-V output I/O pins. 100-MHz minimum operation with 10- pF external loads. The stand-alone ReBiLS chip will allow system designers to provide efficient bi-directional communication between components operating at different voltages. Embedding the ReBiLS cells into the proven Reed-Solomon encoder will demonstrate the ability to support new product development in a commercially viable, rad-hard, scalable 180-nm SOI CMOS process
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