Concerto For Piano vs. Orchestra: Can Tax and Financial Accounting Harmonize on Hedges?

The preference for fair value accounting, for marking items to market for financial reporting or tax purposes, has been particularly strong in the last decade, and has become almost doctrine among accounting standards setters as the preferred method of accounting for financial instruments. Though a similar trend can be documented for tax accounting, the longstanding preference for correlating tax liability with realization events continues to prevent consistency. Also preventing consistency are the myriad difficulties in distinguishing capital gain from ordinary income (where embedded derivatives seem to make the result almost arbitrary), those equally subtle difficulties in distinguishing debt from equity (where derivatives appear often to be neither or both), and, particularly recently, the differences between tax systems of different countries in which transactions are made to occur (with some countries still struggling to educate tax officials about derivatives). These inconsistencies, which in the fertile imaginations of tax lawyers become tax shelters, would largely disappear if fair value accounting were universal in the tax law. One could argue for a sort of global marking to market on December 31 -a single calendar year for all taxpayers would also be helpful-with all countries agreeing to tax the difference from the year before at 28 percent, allocating the result between themselves under some universally applied transfer pricing formula. Assuming that this approach is politically impossible in every country, and that even if a few countries agreed to it, others would not, one can still validly ask whether the advances that have recently been made in financial accounting hold any lessons for tax accounting. To be somewhat more limited, can the Statement of Financial Accounting Standard No. 133 (SFAS 133), Accounting for Derivative Instruments and Hedging Activities, provide any guidance for Congress as to some appropriate alterations of the U.S. tax system? It will be. the purpose of this paper to review the deferral system provided by the hedge accounting allowed by SFAS 133, and to compare this system against those tax deferrals that can be obtained under the U.S. tax system

Noncontacting devices to indicate deflection and vibration of turbopump internal rotating parts

Published report discusses feasibility of ultrasonic techniques; neutron techniques; X-radiography; optical devices; gamma ray devices; and conventional displacement sensors. Use of signal transmitters in place of slip rings indicated possible improvement and will be subject of futher study

Noncontacting device to indicate deflection of turbopump internal rotating parts

Phase 2 (development) which was concluded for the ultrasonic Doppler device and the light-pipe-reflectance device is reported. An ultrasonic Doppler breadboard system was assembled which accurately measured runout in the J-2 LOX pump impeller during operation. The transducer was mounted on the outside of the pump volute using a C-clamp. Vibration was measured by conducting the ultrasonic wave through the volute housing and through the fluid in the volute to the impeller surface. The impeller vibration was also measured accurately using the light-pipe probe mounted in an elastomeric-gland fitting in the pump case. A special epoxy resin developed for cryogenic applications was forced into the end of the fiber-optic probe to retain the fibers. Subsequently, the probe suffered no damage after simultaneous exposure to 2150 psi and 77 F. Preliminary flash X-radiographs were taken of the turbine wheel and the shaft-bearing-seal assembly, using a 2-megavolt X-ray unit. Reasonable resolution and contrast was obtained. A fast-neutron detector was fabricated and sensitivity was measured. The results demonstrated that the technique is feasible for integrated-time measurements requiring, perhaps, 240 revolutions to obtain sufficient exposure at 35,000 rpm. The experimental verification plans are included

Place-Based Engagement on Chicago\u27s Northeast Side

Loyola University Chicago (LUC) is a Jesuit university with a mission to prepare students to “set the world on fire” by promoting justice in the world. Led by its School of Education, LUC has worked to engage this mission in its emerging work with public school partners guided by core principles of mutual benefit among partners, place-based engagement within our communities, and a focus on sustainable relationships. While serving others represents the genotype of our 150-year-old Jesuit university and community and civic engagement represents its phenotype, the last ten years has seen change in the university’s phenotype through dramatic growth in both the strategic approach of its place-based engagement commitments and its direct work among multiple community schools. In 2011, the School of Education engineered a radical overhaul of its teacher preparation program moving from a traditional approach to teacher education that was campus- and text-based to a field-based apprenticeship model (Heineke & Ryan, 2018). To achieve this ambitious project, the School of Education generated and solidified relationships with 20-25 core school partners where field-based learning could take place. Transformation of the teacher preparation program coincided with a comprehensive school-university partnership at a neighborhood-based public high school that currently features more than 20 academic initiatives. In 2016, LUC introduced Schools 2020 to build on this success with five additional public schools. In 2018, LUC began to serve as the Lead Partner Agency (LPA) at six Chicago Public Schools (CPS) Community School Initiatives (CSI) sites. Currently more than 1000 students are served through out-of-school (OST) programs while 100 part-time instructors (LUC faculty and students, school teachers, and community organization staff ) work with students through more than 100 unique program activities. More than $4 million in CPS-CSI funding has been secured through 2024 to support this work. In this article, we seek to present the historical context in which our university-school partnership emerged and has developed, our approaches to and examples of the work, discuss challenges that have surfaced in the work and, finally, describe horizon opportunities for LUC. We argue here for a place-based, mutually beneficial approach to university-school partnerships that places relationships at the center of the work in order to achieve sustainability over time. We believe that relationships based in trust and mutuality throughout and across our institutions lead to powerful outcomes for faculty, teachers, students, and ultimately communities. We argue here that a focus on relationships can lead to organizational and community transformation in ways that transactional operational systems may not

Draft Genome Sequence of Lactobacillus jensenii Strain UMB7766, Isolated from the Female Bladder

Lactobacillus jensenii is a beneficial and prominent community member within both the vaginal and female urinary microbiota. As more genomes for L. jensenii strains are made publicly available, we gain more knowledge about this beneficial community member. Here, we present the draft genome sequence of L. jensenii UMB7766, which was isolated from a urine specimen from a catheterized female patient with recurrent urinary tract infections

Bacteriophages of the Lower Urinary Tract

Phages are vital members of the microbiota, having critical roles in shaping bacterial metabolism and community structure. Although phages have been discovered in the urinary tract, such as phages that infect Escherichia coli, sampling them is challenging owing to low biomass, possible contamination when using non-invasive methods and the invasiveness of methods that reduce the potential for contamination. Phages could influence bladder health, but an understanding of the association between phage communities, bacterial populations and bladder health is in its infancy. However, evidence suggests that phages can defend the host against pathogenic bacteria and, therefore, modulation of the microbiome using phages has therapeutic potential for lower urinary tract symptoms. Furthermore, as natural predators of bacteria, phages have garnered renewed interest for their use as antimicrobial agents, for instance, in the treatment of urinary tract infections

Draft Genome Sequence of Streptococcus anginosus UMB1296, Isolated from the Female Urinary Tract

We present the draft genome sequence of a Streptococcus anginosus strain isolated from the female urinary tract. The S. anginosus UMB1296 draft genome has a size of 1,924,009 bp assembled into 35 contigs with a GC content of 38.69%. Genome annotation revealed 1,775 protein-coding genes, including several known virulence factors

Pennsylvania Folklife Vol. 30, No. 2

• A Search for the Origin of the Pennsylvania Barn • A Forebay Bank Barn in Texas • The Swiss Bank House Revisited: Messerschmidt-Dietz Cabin • Paul R. Wieand, Lehigh County Folk Artist • Aldes un Neies / Old & Newhttps://digitalcommons.ursinus.edu/pafolklifemag/1090/thumbnail.jp

Draft Genome Sequence of Lactobacillus mulieris UMB9245, Isolated from the Female Bladder

Lactobacillus jensenii is an anaerobic bacterium found in the urogenital tract that is known to prevent common vaginal infections. Recently, it was divided into two species, L. jensenii and L. mulieris. Here, we report the draft genome sequence of L. mulieris UMB9245, with a genome length of 1,723,383 bp assembled into 52 contigs

Draft Genome Sequence of Enterococcus faecalis UMB7780, Isolated from the Female Urinary Tract

Here, we present the draft genome sequence of Enterococcus faecalis UMB7780, isolated from the female urinary tract. The genome size is 3,005,901 bp, with a GC content of 37.36%, genome coverage of 179×, and an N50 score of 169,627 bp. Genome analysis identified evidence of antibiotic resistance, as well as intact prophages