1,441 research outputs found

    Interpreting Settler Infrastructure in Stevens County, Minnesota: Gager\u27s Station and the Post Dakota-US War of 1862 Frontier

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    Gager\u27s Station is a little known, but formative settler infrastructure project from the 1860s in west-central Minnesota. Gager\u27s Station was situated along both an important military supply route, and lands of significant importance to the Indigenous people of the area. Gager\u27s Station bears several similarities to the scout camps and civilian defense forts in the broader Fort Wadsworth network that provided civilian defense to new homesteaders following the Dakota-US War of 1862. Fort Wadsworth served as another goal post in western expansion of the United States. Further, the networks of forts that supported it appeased the anxious settlers who feared Dakota uprising levels of reprisal from people who no longer lived in their settlements. The following is a synthesis of the historical and archaeological record of Fort Wadsworth network and how Gager\u27s Station fits into the broader goals of the colonial project in the upper Midwest.https://digitalcommons.morris.umn.edu/urs_2022/1000/thumbnail.jp

    Location Savings and Segmented Factor Input Markets: In Search of a Tax Treaty Solution

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    This article analyzes the proper bounds of source-based taxation of profits generated when firms outsource factor inputs, such as labor, to achieve cost savings. The article advances arguments grounded in efficiency, treaty text, and international distribution to justify greater source-based taxation than has historically been the case. To implement such expanded taxation, the article proposes a modification to transfer-pricing rules in instances where factor inputs are acquired from affiliates and a modification to the tax treaty rules regarding permanent establishments where factor inputs are acquired from unrelated parties. Finally, the article deals with a range of complications, particularly relating to measurement of economic rents from low cost factor inputs over time and tax competition

    Effect of water injection on boiler performance

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    A 20kW commercial boiler has been modified to enable the injection of water into its combustion air, with the aim of reducing the emissions of carbon monoxide (CO) and oxides of nitrogen (NOx) and increasing heat transfer efficiency.It was identified that water injection had been used for efficiency and emissions control in both gas turbine and internal combustion engines. NOx reductions were consistently achieved however CO reductions were application dependant. The lack of literature relating to water injection in boilers provided an opportunity for novel research.An experimental setup was designed to investigate the effect of water injected into the combustion air on the heat-transfer efficiency of the boiler system, as well as its emissions of CO and NOx. The differences between liquid water and steam, injecting at points internal and external to the burner, and with or without the use of nozzles was also explored.NOx and CO reductions of up to 40% and 93% were achieved with water injected inside the burner through a nozzle with no significant change in heat-transfer efficiency. The CO reduction effectiveness was found to be dependent on several factors. These included: the method and location of the injection, whether the fluid was vaporised, and the air-to-fuel equivalence ratio. The majority of experimental cases resulted in NOx reductions.</div

    Corporate Taxation and International Charter Competition

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    Corporate Charter competition has become an increasingly international phenomenon. The thesis of this article is that this development in the corporate law requires a greater focus on the corporate tax law. We first demonstrate how a tax system’s capacity to distort the international charter market depends both upon its approach to determining corporate location and the extent to which it taxes foreign source corporate profits. We also show, however, that it is not possible to remove all distortions through modifications to the tax system alone. We present instead two alternative methods for preserving an international charter market. The first best solution involves severing the markets for corporate law and corporate tax law through coordination of locational rules under each regime, with a “place of incorporation” rule for corporate law and a “real seat” rule for corporate tax. The second best solution relies on a properly designed federal structure. The crucial design elements for such a federal system are the allocation of substantive law between the federal and subfederal levels, corporate and corporate tax locational rules, and the taxation of corporate migration and foreign source corporate profits. With due attention to these details, an international charter market can be protected from the potentially distorting effects of corporate taxation, but only if considerable care is taken. In the final part of the paper we apply our analysis to the United States, Canada, the European Union, and Israel, and show how difficult it is, in the real world, to separate corporate charter and corporate tax competition

    Corporate Taxation and International Charter Competition

    Get PDF
    Corporate Charter competition has become an increasingly international phenomenon. The thesis of this article is that this development in the corporate law requires a greater focus on the corporate tax law. We first demonstrate how a tax system’s capacity to distort the international charter market depends both upon its approach to determining corporate location and the extent to which it taxes foreign source corporate profits. We also show, however, that it is not possible to remove all distortions through modifications to the tax system alone. We present instead two alternative methods for preserving an international charter market. The first best solution involves severing the markets for corporate law and corporate tax law through coordination of locational rules under each regime, with a “place of incorporation” rule for corporate law and a “real seat” rule for corporate tax. The second best solution relies on a properly designed federal structure. The crucial design elements for such a federal system are the allocation of substantive law between the federal and subfederal levels, corporate and corporate tax locational rules, and the taxation of corporate migration and foreign source corporate profits. With due attention to these details, an international charter market can be protected from the potentially distorting effects of corporate taxation, but only if considerable care is taken. In the final part of the paper we apply our analysis to the United States, Canada, the European Union, and Israel, and show how difficult it is, in the real world, to separate corporate charter and corporate tax competition

    Corporate Taxation and International Charter Competition

    Get PDF
    Corporate charter competition has become an increasingly international phenomenon. The thesis of this Article is that this development in corporate law requires a greater focus on corporate tax law. We first demonstrate how a tax system\u27s capacity to distort the international charter market depends both upon its approach to determining corporate location and upon the extent to which it taxes foreign source corporate profits. We also show, however, that it is not possible to remove all distortions through modifications to the tax system alone. We present instead two alternative methods for preserving an international charter market. The first-best solution involves severing the markets for corporate law and corporate tax law through coordination of locational rules under each regime, with a place of incorporation rule for corporate law and a real seat rule for corporate tax. The second-best solution relies on a properly designed federal structure. The crucial design elements for such a federal system are the allocation of substantive law between the federal and subfederal levels, corporate and corporate tax locational rules, and the taxation of corporate migration and foreign source corporate profits. With due attention to these details, an international charter market can avoid the potentially distorting effects of corporate taxation. In the final part of the Article we apply our analysis to the United States, Canada, the European Union, and Israel, and show how difficult it is, in the real world, to separate corporate charter and corporate tax competition

    Identification of sleep apnea events using discrete wavelet transform of respiration, ECG and accelerometer signals

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    Sleep apnea is a common sleep disorder in which patient sleep patterns are disrupted due to recurrent pauses in breathing or by instances of abnormally low breathing. Current gold standard tests for the detection of apnea events are costly and have the addition of long waiting times. This paper investigates the use of cheap and easy to use sensors for the identification of sleep apnea events. Combinations of respiration, electrocardiography (ECG) and acceleration signals were analysed. Results show that using features, formed using the discrete wavelet transform (DWT), from the ECG and acceleration signals provided the highest classification accuracy, with an F1 score of 0.914. However, the novel employment of just the accelerometer signal during classification provided a comparable F1 score of 0.879. By employing one or a combination of the analysed sensors a preliminary test for sleep apnea, prior to the requirement for gold standard testing, can be performed

    From the editors

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    Introduction to Volume 2, Issue 2 by the new Senior Student Editors

    Youths Perceive Some Improvement in Substance Abuse Prevention Knowledge, Skills, and Assets from Participation in 4-H Health Rocks!

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    The 4-H Health Rocks! curriculum aims to reduce use of tobacco, alcohol, and other drugs and promote healthful lifestyle choices among 8- to 14-year-old youths. A retrospective post-then-pre survey of Tennessee participants was aimed at describing the demographic characteristics of participants and investigating respondents\u27 perceptions of program outcomes. Although positive, significant results in youths\u27 perceived knowledge, skills, and assets were found, the majority of youths reported no change from before program participation to after program participation. Recommendations include addressing the need for additional research that aligns respondents\u27 perceptions with program delivery settings and the need to explore different evaluation approaches

    The Phenomenology of a Hidden Symmetry Breaking Sector

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    We calculate the production rate of gauge-boson pairs at the SSC in a model with a ``hidden'' electroweak symmetry breaking sector. We show that the signal of electroweak symmetry breaking is lower than the background and that we cannot necessarily rely on gauge boson pairs as a signal of the dynamics of symmetry breaking.Comment: harvmac, 8 pages (4 figures), BUHEP-92-23 new version corrects error in figure
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