Crisis-Driven Tax Law: The Case of Section 382

At the peak of the 2008 financial crisis, the Internal Revenue Service (IRS) issued Notice 2008–83 (the Notice), administrative guidance that limited Internal Revenue Code (the Code) section 382, an important tax rule designed to discourage tax-motivated acquisitions. Although styled as a mere interpretation of existing law, the Notice has been widely viewed as an improper exercise of the IRS’s authority that undermined its legitimacy. But did the Notice work? There were many extraordinary interventions during the financial crisis that raised questions about eroding the rule of law and the long-term destabilizing effects of bail­outs. In a financial crisis, regulators must weigh these real, but distant and uncertain, costs against the immediate benefits of the intervention. Toward that end, we report the first evidence of the effects of limiting Code section 382 during the 2008 financial crisis. Although we find lit­tle evidence that the Notice affected bank merger activity, those merg­ers that occurred while the Notice was in effect produced lower post-merger income growth. The results suggest that Code section 382 may have some benefits in terms of discouraging tax-motivated acqui­sitions. We use the Notice to illustrate the concerns that should guide lawmakers’ decisions about if and how to make law during a crisis

Crisis-Driven Tax Law: The Case of Section 382

At the peak of the 2008 financial crisis, the Internal Revenue Service (IRS) issued Notice 2008–83 (the Notice), administrative guidance that limited Internal Revenue Code (the Code) section 382, an important tax rule designed to discourage tax-motivated acquisitions. Although styled as a mere interpretation of existing law, the Notice has been widely viewed as an improper exercise of the IRS’s authority that undermined its legitimacy. But did the Notice work? There were many extraordinary interventions during the financial crisis that raised questions about eroding the rule of law and the long-term destabilizing effects of bailouts. In a financial crisis, regulators must weigh these real, but distant and uncertain, costs against the immediate benefits of the intervention. Toward that end, we report the first evidence of the effects of limiting Code section 382 during the 2008 financial crisis. Although we find little evidence that the Notice affected bank merger activity, those mergers that occurred while the Notice was in effect produced lower post-merger income growth. The results suggest that Code section 382 may have some benefits in terms of discouraging tax-motivated acquisitions. We use the Notice to illustrate the concerns that should guide lawmakers’ decisions about if and how to make law during a crisis

Uncollapsing the wavefunction by undoing quantum measurements

We review and expand on recent advances in theory and experiments concerning the problem of wavefunction uncollapse: Given an unknown state that has been disturbed by a generalized measurement, restore the state to its initial configuration. We describe how this is probabilistically possible with a subsequent measurement that involves erasing the information extracted about the state in the first measurement. The general theory of abstract measurements is discussed, focusing on quantum information aspects of the problem, in addition to investigating a variety of specific physical situations and explicit measurement strategies. Several systems are considered in detail: the quantum double dot charge qubit measured by a quantum point contact (with and without Hamiltonian dynamics), the superconducting phase qubit monitored by a SQUID detector, and an arbitrary number of entangled charge qubits. Furthermore, uncollapse strategies for the quantum dot electron spin qubit, and the optical polarization qubit are also reviewed. For each of these systems the physics of the continuous measurement process, the strategy required to ideally uncollapse the wavefunction, as well as the statistical features associated with the measurement is discussed. We also summarize the recent experimental realization of two of these systems, the phase qubit and the polarization qubit.Comment: 19 pages, 4 figure

Atopic dermatitis, cutaneous steroids and cataracts in children: two case reports

<p>Abstract</p> <p>Introduction</p> <p>Atopic dermatitis is a chronic, pruritic, eczematous skin disease mediated through an immediate (type I) hypersensitivity reaction. Posterior sub-capsular cataracts are a recognised complication of atopic dermatitis in adults; however they are rare in children. The management of atopic dermatitis is based on the exclusion of allergens, the use of emollients, and on topical corticosteroids for disease exacerbations. Cataracts may be due to atopic dermatitis but may also occur secondary to the use of corticosteroids.</p> <p>Case presentation</p> <p>We describe two children with atopic dermatitis, treated with cutaneous corticosteroids, both of whom were diagnosed with bilateral posterior sub-capsular cataracts.</p> <p>Conclusion</p> <p>These cases demonstrate that atopic dermatitis and topical corticosteroids may be associated with cataracts in children as well as adults. The cause of cataracts in atopic dermatitis is not known, however, it has been suggested that habitual tapping and rubbing of the face may play a role. Care needs to be taken when prescribing corticosteroids. Inadequate treatment of atopic dermatitis may lead to other ocular complications such as keratitis and permanent visual loss.</p

Treatment Pathway of Bone Sarcoma in Children, Adolescents, and Young Adults

When pediatric, adolescent, and young adult patients present with a bone sarcoma, treatment decisions, especially after relapse, are complex and require a multidisciplinary approach. This review presents scenarios commonly encountered in the therapy of bone sarcomas with the goal of objectively presenting a consensus, multidisciplinary management approach. Little variation was found in the authors\u27 group with respect to local control or systemic therapy. Clinical trials were universally prioritized in all settings. Decisions regarding relapse therapies in the absence of a clinical trial had very minor variations initially, but a consensus was reached after a literature review and discussion. This review presents a concise document and figures as a starting point for evidence-based care for patients with these rare diseases. This framework allows prospective decision making and prioritization of clinical trials. It is hoped that this framework will inspire and focus future clinical research and thus lead to new trials to improve efficacy and reduce toxicity

Penguin-Diagram Induced B→KXϕB \rightarrow K_X\phi Decays in the Standard Model and in the Two-Higgs-Doublet Model

We systematically analyse the gluonic penguin-induced charmless decays B \ra K_X\phi($K_X$ denotes the meson state $s\bar q \;(q=u\ {\rm or}\ d)$ ), in the standard model and the two-Higgs-doublet model. These processes, being induced at one-loop level, are of great importance in measuring the virtual top quark effect in the standard model, and also in searching for the non-standard signals in the low energy region. It is shown that the QCD effect is also significant in these processes, as in the weak radiative processes B \ra X_s \gamma. We also show that the charged Higgs contribution can not provide sizable enhancements for the decays B \ra K_X\phi, in contrast to the decays B \ra K_X\gamma. It is also found that processes such as B \ra K_1(1400)\phi and B \ra K(1460)\phi have large branching fractions among B \ra K_X\phi decays.Comment: 18pages, Latex. Paper (Hayashi, Takemi et al. AUE-02-93) is replaced with reviced version Jan 1994 and aloso the title is change

Merger Histories of Galaxy Halos and Implications for Disk Survival

We study the merger histories of galaxy dark matter halos using a high resolution LCDM N-body simulation. Our merger trees follow ~17,000 halos with masses M_0 = (10^11--10^13) Msun at z=0 and track accretion events involving objects as small as m = 10^10 Msun. We find that mass assembly is remarkably self-similar in m/M_0, and dominated by mergers that are ~10% of the final halo mass. While very large mergers, m > 0.4 M_0, are quite rare, sizeable accretion events, m ~ 0.1 M_0, are common. Over the last 10 Gyr, an overwhelming majority (~95%) of Milky Way-sized halos with M_0 = 10^12 Msun have accreted at least one object with greater total mass than the Milky Way disk (m > 5x10^10 Msun), and approximately 70% have accreted an object with more than twice that mass (m > 10^11 Msun). Our results raise serious concerns about the survival of thin-disk dominated galaxies within the current paradigm for galaxy formation in a CDM universe. In order to achieve a ~70% disk-dominated fraction in Milky Way-sized CDM halos, mergers involving m ~ 2x10^11 Msun objects must not destroy disks. Considering that most thick disks and bulges contain old stellar populations, the situation is even more restrictive: these mergers must not heat disks or drive gas into their centers to create young bulges.Comment: 14 pages, 10 figures. This version accepted for publication in ApJ. v2 and v3 fixed typos and mislabels, v4 restructured and expanded the discussion section, added fitting functions to appendix, and other minor changes. Results and primary conclusions remain unchange

Coordinated generation of multiple ocular-like cell lineages and fabrication of functional corneal epithelial cell sheets from human iPS cells

We describe a protocol for the generation of a functional and transplantable corneal epithelium derived from human induced pluripotent stem (iPS) cells. When this protocol is followed, a proportion of iPS cells spontaneously form circular colonies, each of which is composed of four concentric zones. Cells in these zones have different morphologies and immunostaining characteristics, resembling neuroectoderm, neural crest, ocular-surface ectoderm, or surface ectoderm. We have named this 2D colony a 'SEAM' (self-formed ectodermal autonomous multizone), and previously demonstrated that cells within the SEAM have the potential to give rise to anlages of different ocular lineages, including retinal cells, lens cells, and ocular-surface ectoderm. To investigate the translational potential of the SEAM, cells within it that resemble ocular-surface epithelia can be isolated by pipetting and FACS sorting into a population of corneal epithelial-like progenitor cells. These can be expanded and differentiated to form an epithelial layer expressing K12 and PAX6, and able to recover function in an animal model of corneal epithelial dysfunction after surgical transplantation. The whole protocol, encompassing human iPS cell preparation, autonomous differentiation, purification, and subsequent differentiation, takes between 100 and 120 d, and is of potential use to researchers with an interest in eye development and/or ocular-surface regeneration. Experience with human iPS cell culture and sorting via FACS will be of benefit for researchers performing this protocol

A meta-analysis of the associations between common variation in the PDE8B gene and thyroid hormone parameters, including assessment of longitudinal stability of associations over time and effect of thyroid hormone replacement

Objective Common variants in PDE8B are associated with TSH but apparently without any effect on thyroid hormone levels that is difficult to explain. Furthermore, the stability of the association has not been examined in longitudinal studies or in patients on levothyroxine (l-T4). Design Totally, four cohorts were used (n=2557): the Busselton Health Study (thyroid function measured on two occasions), DEPTH, EFSOCH (selective cohorts), and WATTS (individuals on l-T4). Methods Meta-analysis to clarify associations between the rs4704397 single nucleotide polymorphism in PDE8B on TSH, tri-iodothyronine (T3), and T4 levels. Results Meta-analysis confirmed that genetic variation in PDE8B was associated with TSH (P=1.64×10−10 0.20 s.d./allele, 95% confidence interval (CI) 0.142, 0.267) and identified a possible new association with free T4 (P=0.023, −0.07 s.d./allele, 95% CI −0.137, −0.01), no association was seen with free T3 (P=0.218). The association between PDE8B and TSH was similar in 1981 (0.14 s.d./allele, 95% CI 0.04, 0.238) and 1994 (0.20 s.d./allele, 95% CI 0.102, 0.300) and even more consistent between PDE8B and free T4 in 1981 (−0.068 s.d./allele, 95% CI −0.167, 0.031) and 1994 (−0.07 s.d./allele, 95% CI −0.170, 0.030). No associations were seen between PDE8B and thyroid hormone parameters in individuals on l-T4. Conclusion Common genetic variation in PDE8B is associated with reciprocal changes in TSH and free T4 levels that are consistent over time and lost in individuals on l-T4. These findings identify a possible genetic marker reflecting variation in thyroid hormone output that will be of value in epidemiological studies and provides additional evidence that PDE8B is involved in TSH signaling in the thyroid