Australian Loan Council: Arrangements and Experience with Bailouts

In most countries, public borrowing by subnational governments is subjected to somerestrictions imposed by the national governments. In a recent study of 53 selectedcountries, researchers at the International Monetary Fund found that all but six countriesimposed such restrictions. 1 Public borrowing by subnational governments was altogetherprohibited in 16 countries, while 19 countries did not allow subnational governments toborrow overseas. The controls in the remaining countries vary in detail and have beenclassified by the authors of the IMF study into the broad categories of administrativecontrols, rule-based controls and cooperative controls.

Transient dynamics of nonlinear magneto-optical rotation

We analyze nonlinear magneto-optical rotation (NMOR) in rubidium vapor subjected to continuously-scanned magnetic field. By varying magnetic-field sweep rate, a transition from traditionally-observed dispersive-like NMOR signals (low sweep rate) to oscillating signals (higher sweep rates) is demonstrated. The transient oscillatory behavior is studied versus light and magnetic-field parameters, revealing a strong dependence of the signals on magnetic-sweep rate and light intensity. The experimental results are supported with density-matrix calculations, which enable quantitative analysis of the effect. Fitting of the signals simulated versus different parameters with a theoretically-motivated curve reveals presence of oscillatory and static components in the signals. The components depend differently on the system parameters, which suggests their distinct nature. The investigations provide insight into dynamics of ground-state coherence generation and enable application of NMOR in detection of transient spin couplings.Comment: 9 pages, 7 figures, Submitted to Physical Review

Substance over Form? Phantom Regulations and the Internal Revenue Code

This paper addresses the appropriate response to tax statutes that call for the issuance of regulations, but that have been ignored by the Secretary. The courts and the IRS have taken the unusual step of treating these statutes as self-executing, notwithstanding the absence of regulations, and have invoked phantom regulations to enforce the statutes. Several commentators have analyzed the Tax Court\u27s and the IRS\u27s approaches, but have focused mostly on cases interpreting delegations found in the Internal Revenue Code. Because those cases themselves are inconsistent, it is not possible to extract a clear rule from analysis of those cases alone. Surprisingly, a close examination of non-tax sources reveals a clear (if imperfect) solution to the problems posed by spurned delegations. This paper examines these overlooked authorities, and concludes that phantom regulations should never be employed by courts, the IRS, or taxpayers. Rather, if the IRS wishes to give effect to a delegation, it must promulgate rules pursuant to the statutorily mandated method (i.e. notice-and-comment rulemaking). Though the IRS has issued informal notices purporting to give effect to statutory delegations, these notices lack the force and effect of law, the government\u27s arguments notwithstanding. If the taxpayer is aggrieved by the Secretary\u27s failure to promulgate regulations, his only recourse is found in section 706(1) of the Administrative Procedure Act, which allows the taxpayer to compel the Secretary to issue regulations

Effect of oxidative stress on ABC transporters: contribution to epilepsy pharmacoresistance

Epilepsy is a neurological disorder affecting around 1%-2% of population worldwide and its treatment includes use of antiepileptic drugs to control seizures. Failure to respond to antiepileptic drug therapy is a major clinical problem and over expression of ATP-binding cassette transporters is considered one of the major reasons for pharmacoresistance. In this review, we have summarized the regulation of ABC transporters in response to oxidative stress due to disease and antiepileptic drugs. Further, ketogenic diet and antioxidants were examined for their role in pharmacoresistance. The understanding of signalling pathways and mechanism involved may help in identifying potential therapeutic targets and improving drug response

Section 7525’s Last Gasps: The Tax Practitioner Privilege and the Selective Waiver Doctrine

Congress blundered badly by defining the Federally Authorized Tax Practitioner privilege by cross-reference to the attorney-client privilege. The relationship between a client and a FATP is wholly different from that between a client and an attorney, and the application of attorney-client principles to the FATP privilege has given rise to confused (and sometimes contradictory) judicial opinions. This paper attempts to stem the confusion with respect to one aspect of the FATP privilege. The proper application of the selective waiver doctrine to the FATP privilege remains an open question, though courts seem poised to reject it. They have rejected it numerous times in the context of attorney-client privilege claims, and generally find the doctrine incompatible with that privilege\u27s basic purposes. This paper argues that courts should accept the selective-waiver doctrine with respect to the FATP privilege, notwithstanding any contrary jurisprudence on the attorney client privilege. Part II briefly discusses the selective waiver doctrine, and outlines the reasons most commonly cited for its adoption or rejection. Part III describes the FATP privilege and details the IRS\u27s and practitioners\u27 common assumption that the selective waiver doctrine will not apply to it. Part IV argues that section 7525\u27s text demands instead that the doctrine always apply to the privilege. Part V examines statements in section 7525\u27s legislative history that may contradict this conclusion

Why Lenity Has No Place in the Income Tax Laws

This Article shows that courts should reject such arguments because the rule of lenity has no place in the construction of the income tax provisions in Subtitle A of the tax code. The rule of lenity makes sense when applied to a statute that compels or prohibits some type of behavior, but income tax provisions do not compel or prohibit anything. Those provisions simply describe consequences associated with particular transactions. Consequently, applying the rule of lenity can lead to anomalous results