U.S. Taxation Of The Value Of Executive Services Performed For Multinational Joint Ventures

Domestic U. S. businesses forming a joint venture with a commonly-controlled foreign affiliates need always to take into account transfer pricing rules, whereby any income, deductions, or credits or one may be reallocated from one of the businesses to the other. This problem provides special concerns with regards to compensation for executive services, where calculation of an arm’s length amount is more difficult, and where other contractual rights may have an impact on the determination of the arm’s length amount. The concept of transfer pricing rules with regard to services was first addressed in 1968 regulations, after which there were temporary regulations in 2003 that were finalized in 2009. However, there are still many issues that have not been addressed, that will need to be resolved in a future set of regulations

Independent assessment of improvements in dementia care and support since 2009

The Department of Health commissioned a team from the London School of Economics and Political Science and the London School of Hygiene and Tropical Medicine to consider progress in dementia care since 2009. We were asked to focus particularly on three areas: improvements in diagnosis and post-diagnostic support, changes in public attitudes, and developments in research. Two major policy documents provide the context: the National Dementia Strategy 2009, which is now finished, and the Prime Minister’s Challenge on Dementia 2012, which superseded it

Monitoring the impact of the DRG payment system on nursing service context factors in Swiss acute care hospitals : study protocol

With this study protocol, a research program is introduced. Its overall aim is to prepare the instruments and to conduct the first monitoring of nursing service context factors at three university and two cantonal hospitals in Switzerland prior to the introduction of the reimbursement system based on Diagnosis Related Groups (DRG) and to further develop a theoretical model as well as a methodology for future monitoring following the introduction of DRGs.Mit diesem Studienprotokoll wird ein Forschungsprogramm eingeführt. Dessen Ziel ist das Vorbereiten der Instrumente und das Durchführen des ersten Monitorings von Pflegekontextfaktoren an drei Universitäts- und zwei Kantonsspitälern in der Schweiz noch vor Einführung der DRG-basierten Finanzierung, sowie darauf aufbauend das Weiterentwickeln des theoretischen Modells und der dazu gehörenden Methodologie für zukünftige Monitorings nach Einführung der DRGs

Informing the design of a randomised controlled trial of an exercise-based programme for long term stroke survivors: lessons from a before-and-after case series study

Background: To inform the design of a randomised controlled trial (RCT) of an exercise-based programme for long term stroke survivors, we conducted a mixed methods before-and-after case series with assessment at three time points. We evaluated Action for Rehabilitation from Neurological Injury (ARNI), a personalised, functionally-focussed programme. It was delivered through 24 hours of one-to-one training by an Exercise Professional (EP), plus at least 2 hours weekly unsupervised exercise, over 12- 14 weeks. Assessment was by patient-rated questionnaires addressing function, physical activity, confidence, fatigue and health-related quality of life; objective assessment of gait quality and speed; qualitative individual interviews conducted with participants. Data were collected at baseline, 3 months and 6 months. Fidelity and acceptability was assessed by participant interviews, audit of participant and EP records, and observation of training. Findings: Four of six enrolled participants completed the exercise programme. Quantitative data demonstrated little change across the sample, but marked changes on some measures for some individuals. Qualitative interviews suggested that small benefits in physical outcomes could be of great psychological significance to participants. Participant-reported fatigue levels commonly increased, and non-completers said they found the programme too demanding. Most key components of the intervention were delivered, but there were several potentially important departures from intervention fidelity. Discussion: The study provided data and experience that are helping to inform the design of an RCT of this intervention. It suggested the need for a broader recruitment strategy; indicated areas that could be explored in more depth in the qualitative component of the trial; and highlighted issues that should be addressed to enhance and evaluate fidelity, particularly in the preparation and monitoring of intervention providers. The experience illustrates the value of even small sample before-and-after studies in the development of trials of complex interventions.PenCLAHRC; NIH

Minkowski's Object: A Starburst Triggered by a Radio Jet, Revisited

We present neutral hydrogen, ultraviolet, optical and near-infrared imaging, and optical spectroscopy, of Minkowski's Object (MO), a star forming peculiar galaxy near NGC 541. The observations strengthen evidence that star formation in MO was triggered by the radio jet from NGC 541. Key new results are the discovery of a 4.9E8 solar mass double HI cloud straddling the radio jet downstream from MO, where the jet changes direction and decollimates; strong detections of MO, also showing double structure, in UV and H-alpha; and numerous HII regions and associated clusters in MO. In UV, MO resembles the radio-aligned, rest-frame UV morphologies in many high redshift radio galaxies (HzRGs), also thought to be caused by jet-induced star formation. MO's stellar population is dominated by a 7.5 Myr-old, 1.9E7 solar mass instantaneous burst, with current star formation rate 0.52 solar masses per year (concentrated upstream from where the HI column density is high). This is unlike the jet-induced star formation in Centaurus A, where the jet interacts with pre-existing cold gas; in MO the HI may have cooled out of a warmer, clumpy intergalactic or interstellar medium as a result of jet interaction, followed by collapse of the cooling clouds and subsequent star formation (consistent with numerical simulations). Since the radio source that triggered star formation in MO is much less luminous, and therefore more common, than powerful HzRGs, and because the environment around MO is not particularly special in terms of abundant dense, cold gas, jet-induced star formation in the early universe might be even more prevalent than previously thought.Comment: 52 pages, 15 figures, accepted for publication in Ap

Crystallization of Hemoglobins II and III of the Symbiont-Harboring Clam Lucina pectinata

Diffraction data to 2.7 A resolution were measured on crystals of the homotetramers of components II and III of the cytoplacmic hemoglobin of the symbiont-harboring clam Lucina pectinata. Even though the crystallization conditions are different and the sequence homology of the two hemoglobins is only 63%, the crystals are isomorphous to each other and to the heterotetramer Hb II/III, implying that the residues primarily involved in the intermolecular interactions and responsible for crystal cohesion may be invariant

The AllWISE Motion Survey, Part 2

We use the AllWISE Data Release to continue our search for WISE-detected motions. In this paper, we publish another 27,846 motion objects, bringing the total number to 48,000 when objects found during our original AllWISE motion survey are included. We use this list, along with the lists of confirmed WISE-based motion objects from the recent papers by Luhman and by Schneider et al. and candidate motion objects from the recent paper by Gagne et al. to search for widely separated, common-proper-motion systems. We identify 1,039 such candidate systems. All 48,000 objects are further analyzed using color-color and color-mag plots to provide possible characterizations prior to spectroscopic follow-up. We present spectra of 172 of these, supplemented with new spectra of 23 comparison objects from the literature, and provide classifications and physical interpretations of interesting sources. Highlights include: (1) the identification of three G/K dwarfs that can be used as standard candles to study clumpiness and grain size in nearby molecular clouds because these objects are currently moving behind the clouds, (2) the confirmation/discovery of several M, L, and T dwarfs and one white dwarf whose spectrophotometric distance estimates place them 5-20 pc from the Sun, (3) the suggestion that the Na 'D' line be used as a diagnostic tool for interpreting and classifying metal-poor late-M and L dwarfs, (4) the recognition of a triple system including a carbon dwarf and late-M subdwarf, for which model fits of the late-M subdwarf (giving [Fe/H] ~ -1.0) provide a measured metallicity for the carbon star, and (5) a possible 24-pc-distant K5 dwarf + peculiar red L5 system with an apparent physical separation of 0.1 pc.Comment: 62 pages with 80 figures, accepted for publication in The Astrophysical Journal Supplement Series, 23 Mar 2016; second version fixes a few small typos and corrects the footnotes for Table

Peri- and postnatal effects of prenatal adenoviral VEGF gene therapy in growth-restricted sheep

Supported by Wellcome Trust project grant 088208 to A.L.D., J.M.W., D.M.P., I.C.Z., and J.F.M. Wellbeing of Women research training fellowship 318 to D.J.C., Scottish Government work package 4.2 to J.M.W., J.S.M., and R.P.A., as well as funding from the National Institute for Health Research University College London Hospitals Biomedical Research Centre A.L.D. and D.M.P., the British Heart Foundation to I.C.Z., and Ark Therapeutics Oy, Kuopio, Finland, which supplied adenovirus vectors free of charge.Peer reviewedPublisher PD

Human Illness from Avian Influenza H7N3, British Columbia

Avian influenza that infects poultry in close proximity to humans is a concern because of its pandemic potential. In 2004, an outbreak of highly pathogenic avian influenza H7N3 occurred in poultry in British Columbia, Canada. Surveillance identified two persons with confirmed avian influenza infection. Symptoms included conjunctivitis and mild influenzalike illness

Dust-Bounded ULIRGs? Model Predictions for Infrared Spectroscopic Surveys

The observed faintness of infrared fine-structure line emission along with the warm far-infrared (FIR) colors of ultraluminous infrared galaxies (ULIRGs) is a long-standing problem. In this work, we calculate the line and continuum properties of a cloud exposed to an Active Galactic Nucleus (AGN) and starburst spectral energy distribution (SED). We use an integrated modeling approach, predicting the spectrum of ionized, atomic, and molecular environments in pressure equilibrium. We find that the effects of high ratios of impinging ionizing radiation density to particle density (i.e. high ionization parameters, or U) can reproduce many ULIRG observational characteristics. Physically, as U increases, the fraction of UV photons absorbed by dust increases, corresponding to fewer photons available to photoionize and heat the gas, producing what is known as a "dust-bounded" nebula. We show that high U effects can explain the "[C II] deficit", the ~1 dex drop in the [C II] 158 micron /FIR ratio seen in ULIRGs when compared to starburst or normal galaxies. Additionally, by increasing U through increasing the ionizing photon flux, warmer dust and thus higher IRAS F(60)/F(100) ratios result. High U effects also predict an increase in [O I]63 micron /[C II] 158 micron and a gradual decline in [O III] 88 micron /FIR, similar to the magnitude of the trends observed, and yield a reasonable fit to [Ne V]14 micron /FIR ratio AGN observations.Comment: 34 pages, 13 figures, accepted for publication in the Astrophysical Journa