The neural basis of metacognitive ability

Ability in various cognitive domains is often assessed by measuring task performance, such as the accuracy of a perceptual categorization. A similar analysis can be applied to metacognitive reports about a task to quantify the degree to which an individual is aware of his or her success or failure. Here, we review the psychological and neural underpinnings of metacognitive accuracy, drawing on research in memory and decision-making. These data show that metacognitive accuracy is dissociable from task performance and varies across individuals. Convergent evidence indicates that the function of the rostral and dorsal aspect of the lateral prefrontal cortex (PFC) is important for the accuracy of retrospective judgements of performance. In contrast, prospective judgements of performance may depend upon medial PFC. We close with a discussion of how metacognitive processes relate to concepts of cognitive control, and propose a neural synthesis in which dorsolateral and anterior prefrontal cortical subregions interact with interoceptive cortices (cingulate and insula) to promote accurate judgements of performance

Formulary Apportionment in the U.S. International Income Tax System: Putting Lipstick on a Pig?

Perhaps surprisingly, this Article has shown that the debate over formulary apportionment is little more than an alternative path to the larger debate over worldwide taxation versus territorial taxation. The present U.S. international income tax regime for U.S. MNEs is an implicit, overly-generous, and incoherent quasi-territorial system that relies on residence rules, source rules, and the arm’s-length approach to apportion international business profits between domestic income that is currently taxable by the United States and foreign income that is effectively exempt, or nearly so, from U.S. taxation because of deferral and cross-crediting. This version of territoriality is quite ugly because it is highly complex and it imposes only modest restraints on the ability of U.S. MNEs to shift income out of the U.S. tax base to low-tax foreign countries. Four forms of explicit territoriality have been proposed as alternatives to the current U.S. system. The first is traditional territoriality, which relies on source rules and the arm’s-length approach to apportion international business profits between taxable domestic income and exempt foreign income. This is a simpler regime than the current U.S. system because it confers exemption directly rather than implicitly through deferral and cross-crediting. It does, however, preserve the capacity of taxpayers to shift income to low-tax foreign countries subject only to the modest restraint imposed by the arm’s-length approach. Most importantly, it is inconsistent with the principle of ability-to-pay and it provides a powerful incentive to locate business activity in low-tax foreign countries. The other three forms of territoriality that are currently part of the debate are three-factor, two-factor, and single-factor global formulary apportionment. Each of them is simpler than either the current U.S. system or traditional territoriality, but each of them leaves U.S. MNEs with considerable capacity to accomplish erosion of the U.S. tax base through income shifting and each of them shares the defects of traditional territoriality regarding inconsistency with the ability-to-pay principle and distortion of business activity. Thus, U.S. policy makers are left with a choice between a normatively flawed and distortive territoriality that imposes modest restraints on income shifting through the arm’s-length approach (i.e., both the current U.S. system of de facto territoriality and traditional territoriality) and a simpler but normatively flawed and distortive territoriality that still allows a substantial amount of income shifting (i.e., three-factor, two-factor, and single-factor global formulary apportionment). This unhappy dilemma can be avoided by adopting real worldwide taxation or, alternatively, by keeping the current regime while creating a Subpart F income category for low-taxed foreign income and insulating that category from cross-crediting with a separate foreign tax credit limitation basket. A more limited form of formulary apportionment then should be used for, and tailored to, particular forms of income, such as intangible income and global trading income, that present discrete taxation problems. Nevertheless, when such income is earned by a U.S. MNE, allocation of income to a foreign jurisdiction under this more limited form of formulary apportionment should not ipso facto result in the income being exempted from U.S. taxation

Defending Worldwide Taxation With A Shareholder-Based Definition Of Corporate Residence

This Article argues that a principled, efficient, and practical definition of corporate residence is necessary even if some form of corporate integration is adopted, and that such a definition is a key element in designing either a real worldwide or a territorial income tax system as well as a potential restraint on the inversion phenomenon. The Article proposes that the United States adopt a shareholder-based definition of corporate residence that is structured as follows: 1. A foreign corporation is a U.S. tax resident for any year if fifty percent or more of its shares, determined by vote or value, was beneficially owned by U.S. residents on the last day of the immediately preceding year (or was the average ownership for the year by U.S. residents as determined by averaging U.S. resident ownership on the last day of each quarter of the preceding year). A foreign corporation presumptively satisfies this test if any class of its shares is regularly traded in one or more U.S. public capital markets or is marketed to U.S. persons. 2. This presumption can be rebutted by the foreign corporation showing that U.S. resident beneficial ownership of its shares is below the fifty-percent threshold. 3. The presumption can be overcome in the same way by the IRS if it encounters cases where a foreign corporation that is actually foreign-owned lists a class of shares on a U.S. exchange in order to achieve U.S. resident status for tax-avoidance reasons. This proposed shareholder-ownership test, however, would be an alternate definition; a corporation would continue to be a U.S. tax resident if it were formed under the law of a U.S. jurisdiction. Finally, this Article examines the common objections to a shareholder-based definition of corporate residence and explains why those objections are unpersuasive

Clebsch-Gordan Construction of Lattice Interpolating Fields for Excited Baryons

Large sets of baryon interpolating field operators are developed for use in lattice QCD studies of baryons with zero momentum. Operators are classified according to the double-valued irreducible representations of the octahedral group. At first, three-quark smeared, local operators are constructed for each isospin and strangeness and they are classified according to their symmetry with respect to exchange of Dirac indices. Nonlocal baryon operators are formulated in a second step as direct products of the spinor structures of smeared, local operators together with gauge-covariant lattice displacements of one or more of the smeared quark fields. Linear combinations of direct products of spinorial and spatial irreducible representations are then formed with appropriate Clebsch-Gordan coefficients of the octahedral group. The construction attempts to maintain maximal overlap with the continuum SU(2) group in order to provide a physically interpretable basis. Nonlocal operators provide direct couplings to states that have nonzero orbital angular momentum.Comment: This manuscript provides an anlytical construction of operators and is related to hep-lat/0506029, which provides a computational construction. This e-print version contains a full set of Clebsch-Gordan coefficients for the octahedral grou

Crit Care Med

ObjectivesSerum lactate monitoring is central to risk stratification and management of sepsis and is now part of a potential quality measure. We examined 11-year trends in lactate testing and predictors of failure to measure lactates in patients with severe sepsis.DesignRetrospective cohort study.SettingTwo U.S. academic hospitals.PatientsAdult patients admitted from 2003\ue2\u20ac\u201c2013.InterventionsAnnual rates of lactate measurement were assessed in patients who had blood cultures ordered and patients with severe sepsis, as defined by concomitant ICD-9 codes for infection and organ dysfunction. The approximate time of suspected sepsis was determined by the first blood culture order with concurrent antibiotic initiation. Multivariate analysis was performed to identify predictors of failure to measure lactates in severe sepsis cases in 2013.Measurements and ResultsAmong hospitalizations with blood culture orders, rates of lactate measurement increased from 11% in 2003 to 48% in 2013 (p<0.001 for linear trend). Rates of repeat lactate measurement within 6 hours after lactate levels \ue2\u2030\ua5 4.0 mmol/L increased from 23% to 69% (p<0.001). Patients were progressively less likely to be on vasopressors at the time of first lactate measurement (49% in 2003 vs 21% in 2013, p<0.001). Despite these trends, lactates were measured at the time of suspected sepsis in only 65% of patients with severe sepsis in 2013. On multivariate analysis, hospital-onset of sepsis and hospitalization on a nonmedical service were significant predictors of failure to measure lactates (adjusted ORs 7.56, 95% CI 6.31\ue2\u20ac\u201c9.06 and 2.08, 95% CI 1.76\ue2\u20ac\u201c2.24, respectively).ConclusionsLactate testing has increased dramatically over time and is being extended to patients without overt shock. However, rates of serial lactate testing are still suboptimal and lactates are not being measured in many patients with severe sepsis. Hospital-onset sepsis and nonmedical units may be high-yield targets for quality improvement initiatives.3U54CK00172-04S1/CK/NCEZID CDC HHS/United StatesL30 AI113822/AI/NIAID NIH HHS/United StatesT32 AI007061/AI/NIAID NIH HHS/United StatesT32 AI007061/AI/NIAID NIH HHS/United StatesU54 CK000172/CK/NCEZID CDC HHS/United States2016-08-01T00:00:00Z25962082PMC450624

Templated deprotonative metalation of polyaryl systems : facile access to simple, previously inaccessible multi-iodoarenes

The development of new methodologies to affect non-ortho functionalization of arenes has emerged as a globally important arena for research, which is key to both fundamental studies and applied technologies. Here, a range of simple arene feedstocks (namely, biphenyl, meta-terphenyl, para-terphenyl, 1,3,5-triphenylbenzene and biphenylene) are transformed to hitherto unobtainable multi-iodoarenes via a s-block metal sodium magnesiate templated deprotonative approach. These iodoarenes have potential to be used in a whole host of high impact transformations, as precursors to key materials in the pharmaceutical, molecular electronic and nanomaterials industries. Proving the concept, we have transformed biphenyl to 3,5-bis(N-carbazolyl)-1,1’-biphenyl, a novel isomer of 4,4’-bis(N-carbazolyl)-1,1’-biphenyl (CPB) which is currently widely employed as a host material for organic light-emitting diodes, OLEDs