Convolved Substructure: Analytically Decorrelating Jet Substructure Observables

A number of recent applications of jet substructure, in particular searches for light new particles, require substructure observables that are decorrelated with the jet mass. In this paper we introduce the Convolved SubStructure (CSS) approach, which uses a theoretical understanding of the observable to decorrelate the complete shape of its distribution. This decorrelation is performed by convolution with a shape function whose parameters and mass dependence are derived analytically. We consider in detail the case of the $D_2$ observable and perform an illustrative case study using a search for a light hadronically decaying $Z'$. We find that the CSS approach completely decorrelates the $D_2$ observable over a wide range of masses. Our approach highlights the importance of improving the theoretical understanding of jet substructure observables to exploit increasingly subtle features for performance.Comment: 20 pages, 11 figures. v2. Corrected typo in legend in Figure 5. Updated Figure 11, minor modification to conclusions on discrimination power. v3. Updated to published version. Minor typos correcte

The Legacy of UK Tax Concepts in Canadian Income Tax Law

This article examines a specific category of legal transfers between the United Kingdom and Canada, considering the legacy of UK tax concepts in Canadian income tax law. Two main areas are considered where, in our view, this influence has been most profound: (i) the concept of income deployed for Canadian tax purposes; and (ii) judicial approaches to statutory interpretation and tax avoidance. Although the rules and concepts that Canadian courts and legislatures have adopted in each of these areas have necessarily evolved over time, the path of this evolution as well as current approaches reflect the enduring influence of UK tax concepts on Canadian income tax law. The first substantive section examines the structure and concept of income in Canadian tax law, linking its origins and development to the global and schedular taxes that were adopted in the United Kingdom in 1799 and 1803, and to the source and trust concepts that UK courts have employed to interpret the meaning of income for tax purposes. The next section considers judicial approaches to the interpretation of tax statutes and tax avoidance in Canada, tracing the origins of a strict construction approach to interpretation and a formalistic approach to the characterisation of transactions and relationships to early judicial decisions in the UK, and explaining the influence of this traditional approach on subsequent legislative and judicial developments. The final section concludes that the traditional approach endures, albeit uneasily, in Canadian income tax law in the continuing emphasis on textual interpretation of tax legislation and in the formalist application of the general anti-avoidance rule by the Supreme Court of Canada

An Income-Contingent Financing Program for Ontario

Although the positive externalities associated with higher education favour substantial government support, sound arguments also favour student contributions to the costs of post-secondary education, based on both the private benefits obtained and the regressive impact of general subsidies for higher education. At the same time, the central role that higher education performs as a vehicle for social mobility and the general reluctance of private lenders to finance individual investments in higher education suggest that governments also have an important role to play in the area of student assistance - ensuring that higher education is accessible to all students on the basis of merit, irrespective of financial ability. The need for a well-designed student assistance program is more important than ever. Among many proposals for a restructured student aid system, one of the most promising is to replace existing \u27mortgage-style\u27 student loads with a financing arrangement involving repayment obligations that depend on the student\u27s income after graduation. To the extent that this \u27income-contingent\u27 approach reduces the risk to borrowers with respect to their investments in higher education, it will likely lessen the reluctance that students exhibit with respect to such borrowing. Moreover, where funding covers both the direct costs of higher education as well as living expenses, income-contingent financing programs may enhance accessibility by making higher education effectively free at the point of purchase - offsetting the \u27sticker shock\u27 associated with increased tuition fees as well as living costs which generally exceed the direct costs of higher education. Finally, collection through the income tax should reduce the incidence of nonpayment and dramatically lessen the costs of administering student financial aid. This paper proposes an income-contingent financing program (ICFP) for Ontario to replace the current system of mortgage-style loans, automatic debt remission, and interest and debt relief available under the Ontario Student Assistance Program. Part 1 reviews the current system of government-provided student aid in Ontario, providing an essential foundation for our subsequent proposal for an ICFP. Part 2 examines the experience with ICFPs in Australia, New Zealand, Sweden, and the UK, in order to derive lessons relevant to the design of an ICFP for Ontario. Part 3 considers the essential features of an ICFP, canvassing the competing arguments and making specific recommendations informed by our review of the current system in Ontario and the international experience with ICFPs

Legislated Interpretation and Tax Avoidance in Canadian Income Tax Law

Predictable statutory interpretation helps ensure the reliable operation of contemporary systems of taxation. Tax liabilities that are not clearly expressed and articulated by legislatures lead to over-reliance on litigation as a means to enforce and clarify legislative intent. For this reason, modern legislatures continually amend and draft new tax provisions, reformulating existing rules and introducing new ones to address ever-changing social and economic environments. Moreover, legislatures also respond with amendments directed at judicial decisions with which they disagree, as well as the transactions and arrangements at issue in these cases. As these amended and new rules are then subject to application and interpretation by revenue departments, taxpayers, tax advisors, and the courts, all of which legislatures may respond to through further subsequent amendments, tax legislation at any given time can be regarded as the recursive product of an ongoing dialogue.At the same time, the proliferation of ever-more detailed provisions in tax legislation greatly increases the complexity of these statutes. The consequent tendency toward textual interpretation of tax legislation can facilitate tax avoidance that undermines the capacity of a tax system to raise revenue in a manner that is fair or equitable. For this reason, tax statutes like the Canadian Income Tax Act (ITA) typically combine detailed statutory provisions with more broadly-worded anti-avoidance rules that deny unintended tax advantages that might otherwise result from other statutory provisions. At the apex of these anti-avoidance rules stand general anti-avoidance rules (GAARs) like section 245 of the ITA. Section 245 denies tax benefits resulting from tax-motivated transactions that result in a misuse of other provisions of the ITA or other relevant enactments, or an abuse having regard to these provisions read as a whole.In order to “legislate” statutory interpretation, therefore, legislatures generally employ two different approaches: enacting detailed rules in response to changing circumstances and judicial decisions, while simultaneously directing courts to prevent abusive tax avoidance by applying more generalized standards that require them to go beyond or behind the text of the tax legislation in order to deny tax benefits claimed by taxpayers that conflict with the object, spirit or purpose of these provisions. As this paper explains, judicial experience in Canada demonstrates a tension between these two approaches, since the existence of detailed statutory rules can make courts reluctant to apply a general anti-avoidance rule that requires them to depart from the statutory text.This paper considers the GAAR in section 245 of the ITA as an example of legislated statutory interpretation, explaining the origins and structure of this provision and the extent to which it has shaped the interpretation of Canadian income tax law. Part II provides a background to the GAAR, contrasting the textual and formalist approach to tax statutes that was traditionally adopted by English and Canadian courts with the more purposive and substantive approach adopted by U.S. courts as well as English and Canadian courts in the 1980s and early 1990s. Part III explains the basic structure of the GAAR and the way in which Canadian courts have interpreted key elements of this provision. Part IV reviews key tax avoidance cases after the GAAR was introduced, illustrating a lingering affect of pre-GAAR interpretive approaches in the post-GAAR world, from which the courts have only begun to depart. Part V concludes

Symposium on Tax Avoidance after Canada Trustco and Mathew: Summary of Proceedings

On October 19, 2005, the Supreme Court of Canada released its much-anticipated decisions in The Queen v. Canada Trustco Mortgage Co. and Mathew v. The Queen, the first two cases from Canada\u27s highest court addressing the general anti-avoidance rule (GAAR) in section 245 of the federal Income Tax Act. The Faculty of Law at the University of Toronto hosted a symposium on November 18, 2005, which brought together academics, practitioners, representatives of the Canada Revenue Agency, and Chief Justice Donald Bowman of the Tax Court of Canada to discuss the implications of the decisions. This article summarizes the formal presentations and comments of participants in the proceedings

Senecavirus A in Pigs, United States, 2015

Citation: Hause, B. M., Myers, O., Duff, J., & Hesse, R. A. (2016). Senecavirus A in Pigs, United States, 2015. Emerging Infectious Diseases, 22(7), 1323-1325. doi:10.3201/eid2207.151951Senecavirus A (SVA) has been sporadically identified in pigs with idiopathic vesicular disease in the United States and Canada (1–3). Clinical symptoms observed include ruptured vesicles and erosions on the snout and lameness associated with broken vesicles along the coronary band. A recent report characterized SVA in pigs in Brazil with similar clinical symptoms in addition to a higher proportion of deaths than would be expected in pigs 1–4 days of age (4,5). Several outbreaks of this infection in pigs were reported in the summer of 2015 in the United States; the more severe clinical features resembled those seen in outbreaks in Brazil (6). Subsequent testing by PCR of 2,033 oral fluid samples from material submitted during 441 routine diagnostic testing procedures (from 25 states) identified 5 SVA-positive cases (1%) (7). Besides affecting animal health, SVA infection is notable because its clinical symptoms resemble those caused by foot-and-mouth disease and vesicular stomatitis viruses. When vesicular disease is observed in US swine, mandatory reporting and testing of animals for foreign animal diseases are required

Reciprocity and resilience: teaching and learning sustainable social enterprise through gaming

Against a backdrop of increased global environmental and economic uncertainty, the resilience and sustainability of urban communities is a paramount concern for decision makers. The work presented here aims to explore how teaching and learning around transition initiatives, based upon social enterprise and reciprocity, might be supported by game theory and strategy simulation environments. Key elements for this are the coevolutionary nature of internal and external organisational contexts. The gaming prototype developed here (Exploring Community Resilience, ExCoRe)is based upon an extension of the Prisoner’s Dilemma as a medium for active learning, but is enacted through a multi-player and dynamic environment. The key learning objectives for the game are to introduce a broad concept of reciprocity and collaboration on a systems level, and the importance of an emergent and responsive ‘learning strategy’ for new start-ups and enterprises. The static nature of the traditional strengths, weaknesses, opportunities, and threats (SWOT) approach is challenged and students are encouraged to appreciate, through establishing game strategy, a much more fluid and dynamic relationship between internal and external environments

Trifocal Relative Pose from Lines at Points and its Efficient Solution

We present a new minimal problem for relative pose estimation mixing point features with lines incident at points observed in three views and its efficient homotopy continuation solver. We demonstrate the generality of the approach by analyzing and solving an additional problem with mixed point and line correspondences in three views. The minimal problems include correspondences of (i) three points and one line and (ii) three points and two lines through two of the points which is reported and analyzed here for the first time. These are difficult to solve, as they have 216 and - as shown here - 312 solutions, but cover important practical situations when line and point features appear together, e.g., in urban scenes or when observing curves. We demonstrate that even such difficult problems can be solved robustly using a suitable homotopy continuation technique and we provide an implementation optimized for minimal problems that can be integrated into engineering applications. Our simulated and real experiments demonstrate our solvers in the camera geometry computation task in structure from motion. We show that new solvers allow for reconstructing challenging scenes where the standard two-view initialization of structure from motion fails.Comment: This material is based upon work supported by the National Science Foundation under Grant No. DMS-1439786 while most authors were in residence at Brown University's Institute for Computational and Experimental Research in Mathematics -- ICERM, in Providence, R