A Comparison of the New U.S. Expatriation Tax and the Canadian Departure Tax

The Heroes Earnings Assistance and Relief Tax Act of 2008 amended the anti-avoidance provisions of the Internal Revenue Code for an expatriating taxpayer. The new law requires expatriating taxpayers to report a deemed taxable sale and repurchase of assets at the time that they expatriate. This is a change from the prior law where an expatriating taxpayer could be taxed by the U.S. for ten years after expatriation. The new U.S. rules are similar to rules that have been used by Canada to tax expatriating Canadian residents. This paper sets out the new U.S. rules and compares them to the Canadian departure tax. As can be seen, there are a number of similarities between the two countries’ laws. However, there are also some major differences. The U.S. rules are more limited in application than the Canadian rules. As well as income tax, the U.S. legislators are concerned with estate and gift taxes, whereas the Canadian legislators are not

Value added tax and consumer spending: A graphical description analysis

The US has been considering introducing a National Consumption Tax federally. This would be in addition to the states’ sales taxes. Since a consumption tax would be an added cost to the consumer, it would be expected that there could be some behavioral change by consumers. This paper uses graphs to describe and analyze whether consumers in the UK and Canada altered their behavior when those countries introduced their Value Added Tax (or Goods and Services Tax). Both retail volume and the percentage change from the prior year (on a monthly basis) were used in the graphic depictions. It was found that there was no or little major behavioral change when the new taxes were introduced. However, when the tax rates were changed substantially, consumers did adapt their behavior to take advantage of the changes by engaging in arbitrage behavior. US consumers are likely to act in a similar manner as UK and Canadian consumers

The new United Kingdom statutory residence rules

With the global economy, many US executives are sent to the United Kingdom (UK) and/or other parts for Europe to work for short-term or long-term assignments. Even if based in the United States or continental Europe, executives of global corporations can often work in the UK. These executives can be resident in more than one country under the tax laws of each country in which the executive works. Since the UK taxes persons who are resident in the UK, it is important to ascertain whether the executive is so resident under UK law. Before April 6, 2013 there was no statutory definition of residence in the United Kingdom (UK). Much of the practical definition came from the courts and the government’s publications. There were generally two definitions; ‘resident’ and ‘ordinary resident’. At this time a major tax case, the Gaines-Cooper case, was going through the courts eventually being finally decided in the Supreme Court. It was generally considered that this case gave the impetus to the government to clarify the definition of resident by statute. This statute was the Finance Act 2013 (FA 2013). Section 218 and Schedule 45 FA 2013 set out the new statuary rules for a taxpayer. This paper explains the new rule in detail

Value added tax and inflation: A graphical and statistical analysis

The US has been considering introducing a National Consumption Tax federally. This would be in addition to the states’ sales taxes. Since a consumption tax would be an added cost to the consumer, it would be expected that inflation would be increased. This paper uses graphs and statistical methods to ascertain whether inflation in the UK and Canada was affected by the introduction or change in rate of the Value Added Tax (or Goods and Services Tax). It was found that the introduction of a VAT in the UK showed no significant effect on the rate of change of CPI, whereas the introduction of GST in Canada did have a significant increase in the rate of CPI. It was also found that when the tax rates were changed substantially, inflation was affected; however, modest changes in the tax rate did not affect inflation

The Expatriation Rules of the Heroes Earnings Assistance and Relief Tax Act of 2008

The United States taxes its citizens on their world-wide income. To remove oneself from the U.S. tax system citizens need to expatriate. The Heroes Earnings Assistance and Relief Tax Act of 2008 amended significantly the anti-avoidance provisions of the Internal Revenue Code for an expatriating taxpayer. The new law requires expatriating taxpayers to report a deemed taxable sale and repurchase of assets at the time that they expatriate. This is a change from the prior law where an expatriating taxpayer could be taxed by the U.S. for ten years after expatriation and had a tax avoidance motive. This paper details the new legislation and shows its possible effects

29Si Hyperfine Structure of the E'_\alpha Center in Amorphous Silicon Dioxide

We report a study by electron paramagnetic resonance (EPR) on the E'_\alpha point defect in amorphous silicon dioxide (a-SiO2). Our experiments were performed on gamma-ray irradiated oxygen-deficient materials and pointed out that the 29Si hyperfine structure of the E'_alpha consists in a pair of lines split by 49 mT. On the basis of the experimental results a microscopic model is proposed for the E'_alpha center, consisting in a hole trapped in an oxygen vacancy with the unpaired electron sp3 orbital pointing away from the vacancy in a back-projected configuration and interacting with an extra oxygen atom of the a-SiO2 matrix.Comment: 4 page

Clay-biosurfactant materials as functional drug delivery systems: Slowing down effect in the in vitro release of cinnamic acid

The main objectives of the present paper were the preparation and characterization of new surfactant-modified clays and the evaluation of their potential applicability as drug delivery systems for the oral administration of the cinnamic acid (CA) drug. The organoclays (OC) were prepared by loading different amounts of the biocompatible nonionic polyoxyethylene sorbitan monolaurate surfactant (Tween20) onto K10 montmorillonite (Mt) clay and characterized through the construction of the adsorption isotherms by means of the spectrophotometric method. The performance of the prepared material was verified by gathering the adsorption isotherms of the cinnamic acid onto the Mt/Tween20 organoclay and by monitoring the release profiles in both simulated gastric (SGF) and intestinal fluids (SIF). The quantitative analysis of the adsorption isotherms revealed that the uptake of the aromatic component onto both the blank and Tween20-loaded Mt was governed by positive cooperative processes and that the presence of the bio-surfactant enhanced the loading efficiency of the clay. By relating the raw montmorillonite uptake capability with that of the OC it was assessed that the presence of the bio-surfactant enhanced about 2 times the loading efficiency of the clay. From the XRD characterization of the obtained complexes, the successful intercalation of the drug into the prepared organoclay was demonstrated. Very useful information was obtained by the in vitro release studies, which showed that the release of the drug from both the clay and organoclay was prolonged in comparison with the pharmacokinetics of the free drug. Besides, the intercalation of the surfactant into the nano-carrier ensured the complete release of the CA after oral drug administration and the kinetics of the release process was strongly dependent on the type of drug formulation used, which means that the CA release can be modulated by properly functionalizing the clay surface

Olfactory dysfunction in patients with chronic rhinosinusitis with nasal polyps is associated with clinical-cytological grading severity

Chronic rhinosinusitis with nasal polyps (CRSwNP) is a common inflammatory disorder, affecting about 4% of the worldwide population and strongly impacting the quality of life. CRSwNP is still a challenge for ENT specialists in terms of its unknown pathogenesis, difficulty in management and frequent relapse. Olfactory impairment frequently affects CRSwNP patients. We tested the hypothesis that clinical-cytological grading (CCG) could be associated with olfactory dysfunction. The study was cross-sectional, enrolling 62 patients (37 males, 25 females, mean age 49 years, range 18-83) suffering from newly diagnosed CRSwNP. Olfactory dysfunction was very frequent (about 90%) and did not depend on nasal obstruction as assessed by both polyp size and nasal airflow limitation. A CCG > 4 was the best cutoff value to suspect olfactory dysfunction [area under the ROC curve of 0.831 (0.715 to 0.914)]; in addition, the statistical risk of having dysosmia was over 7-fold higher in subjects with CCG > 4 compared with subjects reporting a CCG < 4 (adjOR 7.46). The present study underlines that olfactory dysfunction is common in CRSwNP patients and demonstrates an association between olfactory dysfunction and inflammation, suggesting that CCG could be useful in the work-up of CRSwNP patients and in suspecting olfactory impairment