A Model Treaty for the Age of BEPS

The OECD’s Base Erosion and Profit Shifting (BEPS) project promises to bring about the most fundamental changes in the international tax regime since its inception in the 1920s. The fundamental idea behind the various BEPS projects is that the OECD has fully embraced the idea that double non-taxation can have as deleterious consequences as double taxation and that therefore the various aspects of the current rules that enable multinational enterprises (MNEs) to achieve double non-taxation should be reconsidered. The BEPS Action Plan, adopted by the OECD in July 2013, sets an ambitious time table for the various items, which are supposed to be achieved either by September 2014 or at the latest by December 2015. While the Action Plan items generally require coordinated action to amend the domestic laws of the member states, the last item envisages an effort to draft a new multilateral tax treaty. This is likely to be a difficult and prolonged process, so in the meantime we would like to offer some tentative suggestions about how the current OECD model should be revised to address not just double taxation but also double non-taxation

U.S. Treaty Anti-Avoidance Rules: An Overview and Assessment

In this article, the authors provide a summary of the anti-avoidance rules in the United States that relate to bilateral tax treaties. Specifically, they focus on treaty-based anti-avoidance rules and discuss whether or not a General Anti-Avoidance Rule would be appropriate in this context

U.S. Treaty Anti-Avoidance Rules: An Overview and Assessment

In this article, the authors provide a summary of the anti-avoidance rules in the United States that relate to bilateral tax treaties. Specifically, they focus on treaty-based anti-avoidance rules and discuss whether or not a General Anti-Avoidance Rule would be appropriate in this context

US Subpart F Legislative Proposals: A Comparative Perspective

This article reviews recent US proposals to amend the US Controlled Foreign Corporation (CFC) rules, also known as Subpart F. It places the US debate in a comparative perspective by describing how the US proposals fit in with developments in other countries that have CFC rules

Real Time Audit – It is the Time to Act?

The U.S. is facing one of its hardest economic crises. Its economy has not recovered from the 2008 downturn, and the light at the end of the tunnel is far, far away. The government and the Internal Revenue Service (“IRS”) are seeking revenue sources in order to reduce its budget deficit. However, raising the income tax rates is politically difficult and may lead to further loss of jobs. In this political situation, it is important to try to find ways to raise more revenue without raising tax rates. One possibility of doing so is “real time audit”: Auditing transactions when they occur, rather than months or years later

A Model Treaty for the Age of BEPS

The OECD’s Base Erosion and Profit Shifting (BEPS) project promises to bring about the most fundamental changes in the international tax regime since its inception in the 1920s. The fundamental idea behind the various BEPS projects is that the OECD has fully embraced the idea that double non-taxation can have as deleterious consequences as double taxation and that therefore the various aspects of the current rules that enable multinational enterprises (MNEs) to achieve double non-taxation should be reconsidered. The BEPS Action Plan, adopted by the OECD in July 2013, sets an ambitious time table for the various items, which are supposed to be achieved either by September 2014 or at the latest by December 2015. While the Action Plan items generally require coordinated action to amend the domestic laws of the member states, the last item envisages an effort to draft a new multilateral tax treaty. This is likely to be a difficult and prolonged process, so in the meantime we would like to offer some tentative suggestions about how the current OECD model should be revised to address not just double taxation but also double non-taxation

Fibulin-4 is essential for maintaining arterial wall integrity in conduit but not muscular arteries

Homozygous or compound heterozygous mutations in fibulin-4 (FBLN4) lead to autosomal recessive cutis laxa type 1B (ARCL1B), a multisystem disorder characterized by significant cardiovascular abnormalities, including abnormal elastin assembly, arterial tortuosity, and aortic aneurysms. We sought to determine the consequences of a human disease-causing mutation in FBLN4 (E57K) on the cardiovascular system and vascular elastic fibers in a mouse model of ARCL1B. Fbln4E57K/E57K mice were hypertensive and developed arterial elongation, tortuosity, and ascending aortic aneurysms. Smooth muscle cell organization within the arterial wall of large conducting vessels was abnormal, and elastic fibers were fragmented and had a moth-eaten appearance. In contrast, vessel wall structure and elastic fiber integrity were normal in resistance/muscular arteries (renal, mesenteric, and saphenous). Elastin cross-linking and total elastin content were unchanged in large or small arteries, whereas elastic fiber architecture was abnormal in large vessels. While the E57K mutation did not affect Fbln4 mRNA levels, FBLN4 protein was lower in the ascending aorta of mutant animals compared to wild-type arteries but equivalent in mesenteric arteries. We found a differential role of FBLN4 in elastic fiber assembly, where it functions mainly in large conduit arteries. These results suggest that elastin assembly has different requirements depending on vessel type. Normal levels of elastin cross-links in mutant tissue call into question FBLN4\u27s suggested role in mediating lysyl oxidase-elastin interactions. Future studies investigating tissuespecific elastic fiber assembly may lead to novel therapeutic interventions for ARCL1B and other disorders of elastic fiber assembly. 2017 © The Authors, some rights reserved

The Creation: Haydn\u27s Drama

This paper focuses on Haydn’s use of drama in regard to his oratorio The Creation. To understand Haydn’s use of drama, we considered three main aspects. The first aspect is the means by which Haydn came about The Creation text and the meaning it held for him. The second aspect is an analysis of the work, particularly looking at text painting, comedic elements, and orchestration. Finally, we will discuss the reception of Haydn’s work and the importance it held in relation to the aesthetics of the time. The Creation was a staple of Haydn’s work, and would prove to be a large influence on future composers, as well as writers and artists