The Role of the Corn Products Doctrine in Foreign Exchange Transactions

Exchange rate gain or loss may result from fluctuations of exchange rates or from formal governmental action such as revaluation and devaluation. In evaluating the significance of foreign exchange transactions and their tax consequences, the types of transactions that produce exchange rate gain or loss must be distinguished. The first type of transaction is currency speculation in which exchange rate gain or loss is the only profit or loss realized. The second type of transaction involves the purchase and sale of inventory in which the exchange rate gain or loss is ancillary to the monetary gain or loss realized on the underlying commercial transaction. The last type is credit transactions involving the borrowing and repayment of foreign currency, which may produce exchange rate gain or loss on the closing of the transaction with currency purchased at a higher or lower exchange rate than at the time the transaction originated. The significant question raised by these foreign exchange transactions is the type of tax treatment to be accorded to the gains and losses realized. Do the gains or losses qualify for ordinary income or loss status or do they qualify for long or short term capital treatment? The answer to this question depends upon several factors including the type of foreign exchange transaction involved, the party\u27s intent, and the status of the individual or corporation undertaking the transaction. The objective of this paper is to examine the tax consequences of foreign exchange transactions and the role played by the Corn Products doctrine in limiting long term capital gains treatment for such transactions

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Is evolutionary theory is incomplete and are we failing to understand phenomena as disparate as ecosystem development and the interplay of genes and culture in shaping human evolution

evoText: A new tool for analyzing the biological sciences

We introduce here evoText, a new tool for automated analysis of the literature in the biological sciences. evoText contains a database of hundreds of thousands of journal articles and an array of analysis tools for generating quantitative data on the nature and history of life science, especially ecology and evolutionary biology. This article describes the features of evoText, presents a variety of examples of the kinds of analyses that evoText can run, and offers a brief tutorial describing how to use it

Binding of NIR-conPK and NIR-6T to Astrocytomas and Microglial Cells: Evidence for a Protein Related to TSPO

PK 11195 and DAA1106 bind with high-affinity to the translocator protein (TSPO, formerly known as the peripheral benzodiazepine receptor). TSPO expression in glial cells increases in response to cytokines and pathological stimuli. Accordingly, [11C]-PK 11195 and [11C]-DAA1106 are recognized molecular imaging (MI) agents capable of monitoring changes in TSPO expression occurring in vivo and in response to various neuropathologies

Isotopes of nitrogen on Mars: Atmospheric measurements by Curiosity's mass spectrometer

Peer Reviewedhttp://deepblue.lib.umich.edu/bitstream/2027.42/102173/1/wong_readme.pdfhttp://deepblue.lib.umich.edu/bitstream/2027.42/102173/2/wong2013_SM_v4b.pdfhttp://deepblue.lib.umich.edu/bitstream/2027.42/102173/3/grl51166.pd

Primordial argon isotope fractionation in the atmosphere of Mars measured by the SAM instrument on Curiosity and implications for atmospheric loss

Peer Reviewedhttp://deepblue.lib.umich.edu/bitstream/2027.42/102170/1/grl51048.pd

The continuum of fetal alcohol spectrum disorders in four rural communities in south africa: Prevalence and characteristics

Prevalence and characteristics of the continuum of diagnoses within fetal alcohol spectrum disorders (FASD) were researched in previously unstudied rural, agricultural, lower socioeconomic populations in South Africa (ZA)

Are mice good models for human neuromuscular disease? Comparing muscle excursions in walking between mice and humans

The mouse is one of the most widely used animal models to study neuromuscular diseases and test new therapeutic strategies. However, findings from successful pre-clinical studies using mouse models frequently fail to translate to humans due to various factors. Differences in muscle function between the two species could be crucial but often have been overlooked. The purpose of this study was to evaluate and compare muscle excursions in walking between mice and humans

Seasonal Variations in Atmospheric Composition as Measured in Gale Crater, Mars

All MSL data used in this manuscript (REMS and SAM) are freely available on NASA's Planetary Data System (PDS) Geosciences Node, from within 6 months after receipt on Earth (http://pds‐geosciences.wustl.edu/missions/msl/). The mixing ratios developed and presented in this paper are available at a publicly available archive (dataverse.org: doi.org/10.7910/DVN/CVUOWW) as cited within the manuscript. The successful operation of the Curiosity rover and the SAM instrument on Mars is due to the hard work and dedication of hundreds of scientists, engineers, and managers over more than a decade. Essential contributions to the successful operation of SAM on Mars and the acquisition of SAM data were provided by the SAM development, operations, and test bed teams. The authors gratefully thank the SAM and MSL teams that have contributed in numerous ways to obtain the data that enabled this scientific work. We also thank NASA for the support of the development of SAM, SAM data analysis, and the continued support of the Mars Science Laboratory mission. The contribution of F. Lefèvre was supported by the Programme National de Planétologie (PNP). R. Navarro‐Gonzalez acknowledges support from the Universidad Nacional Autónoma de México (PAPIIT IN111619). LPI is operated by USRA under a cooperative agreement with the Science Mission Directorate of the National Aeronautics and Space Administration. We thank members of the SAM and larger MSL team for insightful discussions and support. In particular, we thank R. Becker and R. O. Pepin for careful review of data analysis and interpretation. We thank M. D. Smith for discussion of CRISM CO measurements. We thank A. Brunner, M. Johnson, and M. Lefavor for their development of customized data analysis tools used here and in other SAM publications.Peer reviewedPublisher PD

The continuum of fetal alcohol spectrum disorders in a community in South Africa: Prevalence and characteristics in a fifth sample

The prevalence and characteristics of the continuum of diagnoses within fetal alcohol spectrum disorders (FASD) were researched in a fifth sample in a South African community