I Got 99 Problems and They’re All FATCA

Offshore personal income tax evasion accounts for approximately $50 billion in annual lost revenue for the United States. These large sums of money are squirrelled away in tax havens—jurisdictions, such as Aruba, the Cayman Islands, and Dubai, whose laws allow some U.S. citizens to evade paying their U.S. income taxes. Before the Foreign Account Tax Compliance Act (FATCA) was enacted, U.S. citizens could avoid taxes on passive income by not reporting this income to the Internal Revenue Service (IRS). To detect tax evasion, the IRS pursued U.S. citizens with undeclared assets in foreign banks. But the IRS’s quest was largely unsuccessful because foreign financial institutions did not fully report U.S. account holders’ information. While the IRS occasionally discovered offshore accounts, U.S. taxpayers were largely on the “honor system.” Unfortunately, many U.S. taxpayers with offshore accounts have been dishonest. As a result, Congress brought the hammer down with FATCA to combat and, more importantly, prevent tax evasion. This Comment discusses FATCA’s provisions, particularly those that have been heavily criticized. It then explores these criticisms from a domestic and foreign perspective. In doing so, this Comment examines and endorses Intergovernmental Agreements (IGAs) as (1) a solution to FATCA’s shortcomings and (2) a building block for developing a sustainable model of international tax transparency and information reporting. Finally, this Comment argues that the United States should continue working with the Organisation for Economic Co-operation and Development towards the adoption of a multilateral automatic information exchange standard that will enhance tax transparency and reduce tax evasion at an international level

Abrasive Water Jet Machining of Carbon Epoxy Composite

An experimental study of abrasive water jet machining of carbon epoxy composite is presented. Process parameters namely hydraulic pressure, traverse rate, stand-off distance and abrasive mass flow rate are considered for this study. Taguchi approach and analysis of variance are used to study the influence of process parameters on response characteristics including surface roughness and kerf taper. It is found that hydraulic pressure and traverse rate are most significant parameters to control surface roughness and kerf taper. Microscopic features of the machined surfaces are evaluated using scanning electron microscope and compared with sample surfaces machined by conventional method using diamond edge cutter.A set of process parameters is optimised to achieve minimum surface roughness and kerf taper. Confirmation tests are performed to verify the optimum set of process parameters. Defects like delamination, fibre pull out and abrasive embedment are also studied using scanning electron microscope

Comparative Study of Cost and Power Consumption of HVAC System Using Phase Change Material

Phase change materials (PCM) are materials which absorb the latent heat of the surrounding air. They usually have characteristics such as near to constant temperature operating range with high energy density of melting from solidified state. Nowadays, heating ventilation & air conditioning (HVAC) of commercial & domestic buildings, green rooms in pharmaceutical companies is necessary for maintaining desired atmospheric condition inside the building compound for optimum working environment. For doing so, lot of energy is consumed in this process. Therefore, there is a need of reduction in power consumption where PCM finds a huge market. These materials store the latent heat of the net heat available as latent heat thermal energy without increase in its temperature. Thus, there is a large scope for its usage for reducing the heat load for refrigerating effect for a specified area. This paper intends to compare the variation in heat load calculation of air refrigerated areas like that in commercial buildings, domestic purposes, industrial applications etc. with and without the use of PCM materials

A Validated RP-HPLC Method for the Determination of Telmisartan In Bulk and Pharmaceutical Dosage Form

A RP-HPLC method has been developed and validated for the estimation of telmisartan in bulk and pharmaceutical dosage form. A RP-HPLC isocratic separation was achieved on C18 column (250.6 mm i.d., 5m) utilizing a mobile phase comprising of methanol and acetonitrile in the ratio of 90: 10(v/v) and the eluents from the column were detected using a variable wavelength detector at 237nm. The proposed method has permitted the quantification of telmisartan in the linearity range of 20-100g/ml and the flow rate was maintained at 1ml/min. The column was maintained at ambient temperature and the complete separation was achieved for telmisartan in an overall analytical run time of approximately 10 minutes. The retention time of telmisartan was found to be 3.3 minutes. The limit of detection and limit of quantification were found to be 2.82 and 8.54 ?g/ml, respectively. The percentage recovery was found to be in between 87.3 to 103.18%. The method was found to be suitable for the routine quality control analysis of telmisartan in bulk drug and formulation. The method was validated as per ICH guidelines

Analysis of 55 cases of adenomatoid odontogenic tumor in an Indian population and review of literature

This study reviews the demographic, clinical and radiographic features of adenomatoid odontogenic tumor(AOT) diagnosed in an Indian population over 50 years and also evaluate and compare follicular AOT(F-AOT) and extra-follicular AOT(EF-AOT). 55 diagnosed cases of AOT from 1971-2020 were studied retrospectively. The data regarding the age, sex, location, variant of AOT, duration, clinical features, radiographic appearance, treatment and recurrence were collected and analysed. Of the 722 odontogenic tumors diagnosed, 7.6% were AOTs with higher prevalence of extra-follicular (67.3%) than follicular (32.7%) variant. All the tumors were intraosseous with a marked predilection for maxilla over mandible, ratio 2:1. The patients mean age was 19.8 years with slightly higher female predilection (male:female ratio - 1:1.5). The anterior region (76.4%) was more frequently affected and entire quadrant was involved in 21.8% cases. Clinically, asymptomatic, slow-growing swelling was seen in 81.8% cases with duration of 15 days to 10 years. Radiographically, AOT appeared as well-corticated radiolucent lesion. Canine was the most commonly impacted tooth. Recurrence was seen in 3 cases. Interestingly, in this series extra-follicular was twice more common than follicular AOT. Few cases involved the entire quadrant or crossed the midline of either jaws

Computational Design and Optimisation of Pin Fin Heat Sinks with Rectangular Perforations

The benefits of using pin heat sinks (PHSs) with single, rectangular slotted or notched pin perforations, are explored computationally, using a conjugate heat transfer model. Results show that the heat transfer increases monotonically while the pressure drop decreases monotonically as the size of the rectangular perforation increases. Performance comparisons with PHSs with multiple circular perforations show favourable heat transfer and pressure drop characteristics. However, the reduced manufacturing complexity of rectangular notched pins in particular provide strong motivation for their use in practical applications. Detailed parameterisation and optimisation studies into the benefits of single rectangular notch perforations demonstrate the scope for improving heat transfer and reducing mechanical fan power consumption yet further by careful design of pin density and pin perforations in PHSs

Abrasive water jet machining of multidirectional CFRP laminates

Abrasive water jet machining (AWJM) is widely used in aerospace, marine and automotive industries for trimming composites. However, AWJM demonstrates some challenges when cutting carbon fibre reinforced plastic (CFRP) composites materials such as cut accuracy and quality. More experimental work is needed to provide sufficient machinability databases for manufacturing engineers. This paper presents an experimental study and statistical analysis for cutting 2 lay-up configurations of multidirectional CFRP laminates. Different AWJM conditions including jet pressure, feed rate, and standoff distance are experimented using full factorial design of experiments. Machining process responses such as top and bottom kerf width, kerf taper, machinability and surface characteristics have been evaluated using analysis of variance (ANOVA) technique. A process cost model for the AWJM is presented

Association of respiratory symptoms and lung function with occupation in the multinational Burden of Obstructive Lung Disease (BOLD) study

Background Chronic obstructive pulmonary disease has been associated with exposures in the workplace. We aimed to assess the association of respiratory symptoms and lung function with occupation in the Burden of Obstructive Lung Disease study. Methods We analysed cross-sectional data from 28 823 adults (≥40 years) in 34 countries. We considered 11 occupations and grouped them by likelihood of exposure to organic dusts, inorganic dusts and fumes. The association of chronic cough, chronic phlegm, wheeze, dyspnoea, forced vital capacity (FVC) and forced expiratory volume in 1 s (FEV1)/FVC with occupation was assessed, per study site, using multivariable regression. These estimates were then meta-analysed. Sensitivity analyses explored differences between sexes and gross national income. Results Overall, working in settings with potentially high exposure to dusts or fumes was associated with respiratory symptoms but not lung function differences. The most common occupation was farming. Compared to people not working in any of the 11 considered occupations, those who were farmers for ≥20 years were more likely to have chronic cough (OR 1.52, 95% CI 1.19–1.94), wheeze (OR 1.37, 95% CI 1.16–1.63) and dyspnoea (OR 1.83, 95% CI 1.53–2.20), but not lower FVC (β=0.02 L, 95% CI −0.02–0.06 L) or lower FEV1/FVC (β=0.04%, 95% CI −0.49–0.58%). Some findings differed by sex and gross national income. Conclusion At a population level, the occupational exposures considered in this study do not appear to be major determinants of differences in lung function, although they are associated with more respiratory symptoms. Because not all work settings were included in this study, respiratory surveillance should still be encouraged among high-risk dusty and fume job workers, especially in low- and middle-income countries.publishedVersio

Cohort Profile: Burden of Obstructive Lung Disease (BOLD) study

The Burden of Obstructive Lung Disease (BOLD) study was established to assess the prevalence of chronic airflow obstruction, a key characteristic of chronic obstructive pulmonary disease, and its risk factors in adults (≥40 years) from general populations across the world. The baseline study was conducted between 2003 and 2016, in 41 sites across Africa, Asia, Europe, North America, the Caribbean and Oceania, and collected high-quality pre- and post-bronchodilator spirometry from 28 828 participants. The follow-up study was conducted between 2019 and 2021, in 18 sites across Africa, Asia, Europe and the Caribbean. At baseline, there were in these sites 12 502 participants with high-quality spirometry. A total of 6452 were followed up, with 5936 completing the study core questionnaire. Of these, 4044 also provided high-quality pre- and post-bronchodilator spirometry. On both occasions, the core questionnaire covered information on respiratory symptoms, doctor diagnoses, health care use, medication use and ealth status, as well as potential risk factors. Information on occupation, environmental exposures and diet was also collected