International Taxation

The integration of world capital markets carries important implications for the design and impact of tax policies. This paper evaluates research findings on international taxation, drawing attention to connections and inconsistencies between theoretical and empirical observations. Diamond and Mirrlees (1971) note that small open economies incur very high costs in attempting to tax the returns to local capital investment, since local factors bear the burden of such taxes in the form of productive inefficiencies. Richman (1963) argues that countries may simultaneously want to tax the worldwide capital income of domestic residents, implying that any taxes paid to foreign governments should be merely deductible from domestic taxable income. Governments do not adopt policies that are consistent with these forecasts. Corporate income is taxed at high rates by wealthy countries, and most countries either exempt foreign-source income of domestic multinationals from tax provide credits rather than deductions for taxes paid abroad. Furthermore, individual investors can use various methods to avoid domestic taxes on their foreign-source incomes, in the process also avoiding taxes on their domestic-source incomes. Individual and firm behavior also differs from that forecast by simple theories. Observed portfolios are not fully diversified worldwide. Foreign direct investment is common even when it faces tax penalties relative to other investment in host countries. While economic activity, and tax avoidance activity, is highly responsive to tax rates and tax structure, there are many aspects of tax-motivated behavior that are difficult to reconcile with simple microeconomic incentives. There are promising recent efforts to reconcile observations with theory. To the extent that multinational firms possess intangible capital on which they earn returns with foreign direct investment, even small countries may have a degree of market power, leading to fiscal externalities. Tax avoidance is pervasive, generating further fiscal externalities. These concepts are useful in explaining behavior, and observed tax policies, and they also suggest that international agreements have the potential to improve the efficiency of tax systems worldwide.

Notes on the Tax Treatment of Structures

More than three quarters of the United States tangible capital stock represents structures. Tax policies potentially have a major impact on both the level and composition of investment in structures and equipment. This point is explicitly recognized in most discussions of the effects of capital income taxation. Two aspects of the taxation of structures --the relative burden placed on structures as opposed to equipment investment and the non-taxation of owner occupied housing under the income tax -- have attracted substantial attention in recent years. This paper explores these two aspects of the taxation of structures investments. While the tax system may well have a potent impact on the level and composition of structures investment, this paper argues that conventional analyses of these effects are very misleading. We reach two main conclusions. First,under current tax law, certain types of structures investment are very highly tax favored. Structures can be transferred and therefore depreciated more than once, and structures may be readily financed with tax-favored debt. Overall, itis unlikely that a significant bias towards equipment and against structures exists under current law. Second, the conventional view that the tax system is biased in favor of homeownership is wrong. Because of the possibility of "tax arbitrage" between high bracket landlords and low bracket tenants, the tax system has long favored rental over ownership for most households. The 1981 reforms by reducing the top marginal tax rate reduced this bias somewhat.

Orbital transfer vehicle concept definition and system analysis study, 1985. Volume 3: System and program trades

The key system and program trade studies performed to arrive at a preferred Orbital Transfer Vehicle (OTV) system concept and evolutionary approach to the acquisition of the requisite capabilites is documented. These efforts were expanded to encompass a Space Transportation Architecture Study (STAS) mission model and recommended unmanned cargo vehicle. The most important factors affecting the results presented are the mission model requirements and selection criteria. The reason for conducting the OTV concept definition and system analyses study is to select a concept and acquisition approach that meets a delivery requirement reflected by the mission model

Liquid-hydrogen rocket engine development at Aerojet, 1944 - 1950

This program demonstrated the feasibility of virtually all the components in present-day, high-energy, liquid-rocket engines. Transpiration and film-cooled thrust chambers were successfully operated. The first liquid-hydrogen tests of the coaxial injector was conducted and the first pump to successfully produce high pressures in pumping liquid hydrogen was tested. A 1,000-lb-thrust gaseous propellant and a 3,000-lb-thrust liquid-propellant thrust chamber were operated satisfactorily. Also, the first tests were conducted to evaluate the effects of jet overexpansion and separation on performance of rocket thrust chambers with hydrogen-oxygen propellants

Lateral-directional stability and control characteristics of the Quiet Short-Haul Research Aircraft (QSRA)

The results are presented of flight experiments to determine the lateral-directional stability and control characteristics of the Quiet Short-Haul Research Aircraft (QSRA), an experimental aircraft designed to furnish information on various aerodynamic characteristics of a transport type of airplane that makes use of the upper-surface blown (USB) flap technology to achieve short takeoff and landing (STOL) performance. The flight program designed to acquire the data consisted of maneuvers produced by rudder and control-wheel inputs with the airplane in several configurations that had been proposed for landing approach and takeoff operation. The normal stability augmentation system was not engaged during these maneuvers. Time-history records from the maneuvers were analyzed with a parameter estimation procedure to extract lateral-directional stability and control derivatives. For one aircraft configuration in which the USB flaps were deflected 50 deg, several maneuvers were performed to determine the effects of varying the average angle of attack, varying the thrust coefficient, and setting the airplane's upper surface spoilers at a 13 deg symmetrical bias angle . The effects on the lateral characteristics of deflecting the spoilers were rather small and generally favorable. The data indicate that for one test, conducted at low thrust (a thrust coefficient of 0.38), compared with results from tests at thrust coefficients of 0.77 and larger, there was a significant decrease in the lateral control effectiveness, in the yaw damping and in the directional derivative. The directional derivative was also decreased (by about 30 percent) when the average angle of attack of the test was increased from 3 to 16 deg

Costs of Chronic Waterborne Zinc Exposure and the Consequences of Zinc Acclimation on the Gill/Zinc Interactions of Rainbow Trout in Hard and Soft Water

Juvenile rainbow trout were exposed to zinc in both moderately hard water (hardness 5 120 mg CaCO3/L, pH = 8.0, Zn = 150 μg/L or 450 μg/L) and soft water (hardness = 20 mg CaCO3/L, pH = 7.2, Zn = 50 μg/L or 120 μg/L) for 30 d. Only the 450 mg/L zinc–exposed fish experienced significant mortality (24% in the first 2 d). Zinc exposure caused no effect on growth rate, but growth affected tissue zinc levels. Whole body zinc levels were elevated, but gills and liver showed no consistent increases relative to controls over the 30-d. Therefore, tissue zinc residues were not a good indicator of chronic zinc exposure. After the 30-d exposure, physiological function tests were performed. Zinc was 5.4 times more toxic in soft water (control 96 h LC50s in hard and soft water were 869 μg/L and 162 μg/L, respectively). All zinc-exposed trout had acclimated to the metal, as seen by an increase in the LC50 of 2.2 to 3.9 times over that seen in control fish. Physiological costs related to acclimation appeared to be few. Zinc exposure had no effect on whole body Ca2+ or Na+ levels, on resting or routine metabolic rates, or on fixed velocity sprint performance. However, critical swimming speed (UCrit) was significantly reduced in zinc-exposed fish, an effect that persisted in zinc-free water. Using radioisotopic techniques to distinguish new zinc incorporation, the gills were found to possess two zinc pools: a fast turnover pool (T1/2 = 3–4 h) and a slow turnover pool (T1/2 = days to months). The fast pool was much larger in soft water than in hard water, but at most it accounted for \u3c3.5% of the zinc content of the gills. The size of the slow pool was unknown, but its loading rate was faster in soft water. Chronic zinc exposure was found to increase the size of the fast pool and to increase the loading rate of the slow pool

Automaticity and executive abilities in developmental dyslexia: A theoretical review

Cognitive difficulties are well documented in developmental dyslexia but they present a challenge to dyslexia theory. In this paper, the Model of the Control of Action is proposed as a theoretical explanation of how and why deficits in both automaticity and executive abilities are apparent in the cognitive profiles of dyslexia and how these deficits might relate to literacy difficulties. This theoretical perspective is used to consider evidence from different cognitive domains. The neuroanatomical underpinnings of automaticity and executive abilities are then discussed in relation to the understanding of dyslexia. Links between reading, writing, and executive function are considered. The reviewed evidence suggests that dyslexia theory should consider an interaction between procedural learned behaviour (automaticity) and higher-order (executive) abilities. The capacity to handle environmental interference, develop and engage adaptive strategies accordingly, and plan actions all require interactions between the cerebellum and the prefrontal cortex (PFC). Difficulties in these areas might explain both impairments in the cumulative development of literacy skills in childhood and general task management in everyday life in adulthood. It is suggested that improved measures are required to assess this cerebellar–PFC interaction and to allow early identification of future literacy difficulties, allowing implementation of timely interventions and reasonable adjustments

The Linkage Between Domestic Taxes and Border Taxes

The objective of this paper is to explore to what degree the pattern of border distortions may simply result from each country's attempt to offset the trade distortions created by their domestic tax structure and by other domestic policies.Research Seminar in International Economics, Department of Economics, University of Michiganhttp://deepblue.lib.umich.edu/bitstream/2027.42/100724/1/ECON192.pd