Learning to Live with the New Foreign Nongrantor Trust Rules

The Small Business Job Protection Act of 1996 (the 1996 Act) was intended to deal a heavy blow to the appeal of foreign trusts to U.S. persons. The results were mixed. On the one hand, the 1996 Act imposes an array of reporting requirements, imposes harsh penalties on failures to comply with these requirements, increases the interest charge imposed on taxes paid on distributions of accumulated income from foreign trusts, treats loans of cash from foreign trusts as distributions, and expands the kinds of gifts that can be treated as indirect transfers from foreign trusts. On the other hand, curiously, the 1996 Act encourages the creation of foreign trusts by its adoption of a set of criteria for foreignness that is both more objective than the criteria formerly used and more biased in favor of foreign status. This Article discusses how to create foreign trusts, examines their exposure and the exposure of their U.S. beneficiaries to U.S. income tax, and describes the reporting requirements imposed on their creators, their beneficiaries, and the trusts themselves. In addition to explaining the rules, this Article also considers the extent to which foreign trusts continue to be useful planning tools for U.S. persons

t-channel Approach to Reggeon Interactions in QCD

Starting from the multi-Regge effective action for high-energy scattering in QCD a $t$-channel approach can be developed which is similar to the approach by White based on general Regge arguments. The BFKL kernel of reggeized gluon interaction, contributions to the $2 \rightarrow 4$ reggeized gluon vertex function and the one-loop correction to the BFKL kernel are considered. The conditions are discussed under which this approach can provide a simple estimante of the next-to-leading logarithmic corrections to the BFKL perturbative pomeron intercept.Comment: latex , 17 figures appended as compressed uuencoded eps file

Plasma processing of closed nuclear fuel cycle waste

В работе предложен плазменный метод переработки отходов замкнутого ядерного топливного цикла в виде водно-солеорганической композиции. Этот метод имеет несколько преимуществ и позволяет безопасно перерабатывать такой материал. Определен оптимальный состав для утилизации данного отхода в плазме. Равновесные составы показали, что в процессе плазменной обработки образуются N[2], CO[2], H[2]O, а также FeCl[3] и Fe[2]O[3 в конденсированной фазе. Отсутствие сажи является показателем того, что процесс переработки является экологически безопасным.The work proposed the plasma method of processing closed nuclear fuel cycle wastes in the form of a water-salt-organic composition. This method has several advantages and allows recycling such material safely. The optimal composition for recycling in plasma was determined. Equilibrium compositions showed that in the process of plasma processing N[2], CO[2], H[2]O and also FeCl[3] и Fe[2]O[3] in the condensed phase were formed. Lack of soot is an indicator that the recycling process is environmentally safe

The gluon field of a fast moving nucleus and the effective langrangian for QCD at high energy

Starting from the effective lagrangian for QCD at high energy we calculate the lowest perturbative contributions to the potential of a relativistic nucleus and compare our results to those derived by Kovchegov (see Y.V. Kovchegov, Phys. Rev. {\bf D55}, 5445 (1997)). The results differ already at order g^3 which can be traced to the fact that the meaning of the underlying gluon fields is different. (The effective gluon field we use is a gauge invariant object.) Both approaches should therefore be seen as alternatives, the relative merits of which have to be judged by their phenomenological success.Comment: 13 pages, 4 figures. v2: eq. 18 corrected, modified discussion of the relation between the standard and the effective lagrangian approac

Heavy quark production as sensitive test for an improved description of high energy hadron collisions

QCD dynamics at small quark and gluon momentum fractions or large total energy, which plays a major role for HERA, the Tevatron, RHIC and LHC physics, is still poorly understood. For one of the simplest processes, namely bottom-antibottom production, next-to-leading-order perturbation theory fails. We show that the combination of two recently developed theoretical concepts, the k_perp-factorization and the next-to-leading-logarithmic-approximation BFKL vertex, gives perfect agreement with data. One can therefore hope that these concepts provide a valuable foundation for the description of other high energy processes.Comment: RevTeX, 4 pages, 7 figures titel and abstract changed, several formulations modified in the text, 1 figure droppe

Dissociative recombination and electron-impact de-excitation in CH photon emission under ITER divertor-relevant plasma conditions

For understanding carbon erosion and redeposition in nuclear fusion devices, it is important to understand the transport and chemical break-up of hydrocarbon molecules in edge plasmas, often diagnosed by emission of the CH A^2\Delta - X^2\Pi Ger\"o band around 430 nm. The CH A-level can be excited either by electron-impact or by dissociative recombination (D.R.) of hydrocarbon ions. These processes were included in the 3D Monte Carlo impurity transport code ERO. A series of methane injection experiments was performed in the high-density, low-temperature linear plasma generator Pilot-PSI, and simulated emission intensity profiles were benchmarked against these experiments. It was confirmed that excitation by D.R. dominates at T_e < 1.5 eV. The results indicate that the fraction of D.R. events that lead to a CH radical in the A-level and consequent photon emission is at least 10%. Additionally, quenching of the excited CH radicals by electron impact de-excitation was included in the modeling. This quenching is shown to be significant: depending on the electron density, it reduces the effective CH emission by a factor of 1.4 at n_e=1.3*10^20 m^-3, to 2.8 at n_e=9.3*10^20 m^-3. Its inclusion significantly improved agreement between experiment and modeling

Parton interactions in the Bjorken limit of QCD

We consider the Bjorken limit in the framework of the effective action approach and discuss its similarities to the Regge limit. The proposed effective action allows for a rather simple calculation of the known evolution kernels. We represent the result in terms of two-parton interaction operators involving gluon and quark operators depending on light-ray position and helicity and analyze their symmetry properties.Comment: 32 pages LaTex, 4 eps-figures, comments added, minor correction

The BFKL Pomeron in 2+1 Dimensional QCD

We investigate the high-energy scattering in the spontaneously broken Yang - Mills gauge theory in 2+1 space--time dimensions and present the exact solution of the leading $\ln s$ BFKL equation. The solution is constructed in terms of special functions using the earlier results of two of us (L.N.L. and L.S.). The analytic properties of the $t$-channel partial wave as functions of the angular momentum and momentum transfer have been studied. We find in the angular momentum plane: (i) a Regge pole whose trajectory has an intercept larger than 1 and (ii) a fixed cut with the rightmost singularity located at $j=1$. The massive Yang - Mills theory can be considered as a theoretical model for the (non-perturbative) Pomeron. We study the main structure and property of the solution including the Pomeron trajectory at momentum transfer different from zero. The relation to the results of M. Li and C-I. Tan for the massless case is discussed.Comment: 28 pages LATEX, 3 EPS figures include