The Making of International Tax Law: Empirical Evidence from Tax Treaties Text

We offer the first attempt at empirically testing the level of transnational consensus on the legal language controlling international tax matters. We also investigate the institutional framework of such consensus-building. We build a dataset of 4,052 bilateral income tax treaties, as well as 16 model tax treaties published by the United Nations (U.N.), Organisation for Economic Co-operation and Development (OECD), and the United States. We use natural language processing to perform pair-wise comparison of all treaties in effect at any given year. We identify clear trends of convergence of legal language in bilateral tax treaties since the 1960s, particularly on the taxation of cross-border business income. To explore the institutional source of such consensus, we compare all treaties in effect for any given year to the model treaties in effect during that year. We also explore whether recently concluded treaties converge towards legal language in newly introduced models. We find the OECD Model Tax Convention (OECD Model) to have a significant influence. The years following the adoption of a new OECD Model show a clear trend of convergence in newly adopted bilateral tax treaties towards the language of the new OECD Model. We also find that model treaties published by the U.N. (U.N. Model) have little immediate observable effect, though U.N. treaty policies seem to have a delayed, yet lasting effect. These findings portray the OECD as the institutional source of legal drafting on international tax matters. The normative implications of these findings, however, are not obvious. We offer several normative interpretations for our findings

Phenology of the Diamondback moth (Plutella xylostella) in the UK and provision of decision support for brassica growers

In the UK, severe infestations by Plutella xylostella occur sporadically and are due mainly to the immigration of moths. The aim of this study was to develop a more detailed understanding of the phenology of P. xylostella in the UK and investigate methods of monitoring moth activity, with the aim of providing warnings to growers. Plutella xylostella was monitored using pheromone traps, by counting immature stages on plants, and by accessing citizen science data (records of sightings of moths) from websites and Twitter. The likely origin of migrant moths was investigated by analysing historical weather data. The study confirmed that P. xylostella is a sporadic but important pest, and that very large numbers of moths can arrive suddenly, most often in early summer. Their immediate sources are countries in the western part of continental Europe. A network of pheromone traps, each containing a small camera sending images to a website, to monitor P. xylostella remotely provided accessible and timely information, but the particular system tested did not appear to catch many moths. In another approach, sightings by citizen scientists were summarised on a web page. These were accessed regularly by growers and, at present, this approach appears to be the most effective way of providing timely warnings

A Stage-Specific Enhancer of Immunoglobulin J Chain Gene Is Induced by Interleukin-2 in a Presecretor B Cell Stage

AbstractInterleukin-2 (IL-2)–induced transcription of the J chain gene was used as a model for analyzing cytokine regulation during B cell development. To determine whether IL-2 signals are targeted to a J chain gene enhancer as well as to its promoter, the sequences flanking the J chain gene were first examined for DNase I hypersensitivity. Of six sites identified, two strong ones, 7.5 kb upstream of the J chain gene, were found to be associated with an enhancer that is active only during the antigen-driven stages of B cell development. Further analyses of the enhancer in the IL-2–responsive presecretor BCL1 cells showed that the enhancer is activated at this stage by an IL-2 signal that functions by opening the enhancer chromatin and stimulating STAT5 to bind to a STAT5 element critical for the enhancer induction. Moreover, after this early induction stage, the enhancer was shown to be constitutively open and active in terminally differentiated plasma cells

Bottom-up thermalization in heavy ion collisions

We describe how thermalization occurs in heavy ion collisions in the framework of perturbative QCD. When the saturation scale $Q_s$ is large compared to $\Lambda_{QCD}$, thermalization takes place during a time of order $\alpha^{-13/5}Q_s^{-1}$ and the maximal temperature achieved is $\alpha^{2/5}Q_s$.Comment: 11 pages; acknowledgement added; section IIIB slightly extended, version accepted for publication in Phys. Lett.