Comparative Analysis of Systems of Domestic Taxation of Controlled Foreign Corporations

This Note outlines the existing law and practice of the domestic taxation of CFC\u27s in the United States, United Kingdom, France, West Germany, and Japan, each of which exhibits a high level of economic and industrial advancement. United States developments are important because the statutory provisions of Subpart F have been adopted, with modifications, by other nations, including West Germany and Japan. The United Kingdom and France, on the other hand, have not yet adopted an integrated statutory scheme providing for domestic taxation of CFC\u27s. These countries attack tax evasion schemes utilizing foreign controlled companies primarily through general laws, exchange controls, and the requirement of government consent for certain international transactions

Recent Decisions

CONSTITUTIONAL LAW--COMMERCE CLAUSE--STATE TAX ON INSTRUMENTALITIES OF FOREIGN COMMERCE INVALID WHEN TAX RESULTS IN MULTIPLE TAXATION AND IMPAIRS FEDERAL UNIFORMITY IN REGULATION OF FOREIGN TRADE Jamie S. Martin ----------------------------- IMMIGRATION--LAWFUL UNRELINQUISHED DOMICILE--DEPORTABLE RESIDENT ALIEN MUST ACCUMULATE SEVEN YEARS OFLAWFUL DOMICILE SUBSEQUENT TO ADMISSION FOR PERMANENT RESIDENCE TO BE ELIGIBLE FOR DISCRETIONARY RELIEF Margaret H. Fiorillo ---------------------------------- LONGSHOREMEN\u27S AND HARBOR WORKERS\u27 COMPENSATION ACT--MANUFACTURER MAY SUE STEVEDORE FOR INDEMNIFICATION FROM LIABILITY ARISING OUT OF LONGSHOREMEN\u27S INJURIES--THEORY OF EQUITABLE CREDIT DOES NOT APPLY TO THE LHWCA J. Andrew Hoyal, I

Targetable Mechanical Properties by Switching between Self-Sorting and Co-assembly with In Situ Formed Tripodal Ketoenamine Supramolecular Hydrogels

A new family of supramolecular hydrogelators are introduced in which self-sorting and co-assembly can be utilised in the tuneability of the mechanical properties of the materials, a property closely tied to the nanostructure of the gel network. The in situ reactivity of the components of the gelators allows for system chemistry concepts to be applied to the formation of the gels and shows that molecular properties, and not necessarily the chemical identity, determines some gel properties in these family of gels

Our evolving understanding of the role of the γδ T cell receptor in γδ T cell mediated immunity

The γδ T cell immune cell lineage has remained relatively enigmatic and under-characterised since their identification. Conversely, the insights we have, highlight their central importance in diverse immunological roles and homeostasis. Thus, γδ T cells are considered as potentially a new translational tool in the design of new therapeutics for cancer and infectious disease. Here we review our current understanding of γδ T cell biology viewed through a structural lens centred on the how the γδ T cell receptor mediates ligand recognition. We discuss the limited knowledge of antigens, the structural basis of such reactivities and discuss the emerging trends of γδ T cell reactivity and implications for γδ T cell biology

Grazing reduces bee abundance and diversity in saltmarshes by suppressing flowering of key plant species

Global declines in pollinator populations and associated services make it imperative to identify and sensitively manage valuable habitats. Coastal habitats such as saltmarshes can support extensive flowering meadows, but their importance for pollinators, and how this varies with land-use intensity, is poorly understood. We hypothesised that saltmarshes provide important bee foraging habitat, and that livestock grazing either suppresses or enhances its value by reducing the abundance - or increasing the diversity - of flowering plants. To test these hypotheses, we surveyed 11 saltmarshes in Wales (UK) under varying grazing management (long-term ungrazed, extensively grazed, intensively grazed) over three summers and investigated causal pathways linking grazing intensity with bee abundance and diversity using a series of linear mixed models. We also compared observed bee abundances to 11 common terrestrial habitats using national survey data. Grazing reduced bee abundance and richness via reductions in the flower cover of the two key food plants: sea aster Tripolium pannonicum and sea lavender Limonium spp. Grazing also increased flowering plant richness, but the positive effects of flower richness did not compensate for the negative effects of reduced flower cover on bees. Bee abundances were approximately halved in extensively grazed marshes (relative to ungrazed) and halved again in intensively grazed marshes. Saltmarsh flowers were primarily visited by honeybees Apis mellifera and bumblebees Bombus spp. in mid and late summer. Compared to other broad habitat types in Wales, ungrazed saltmarshes ranked highly for honeybees and bumblebees in July-August, but were relatively unimportant for solitary bees. Intensively grazed saltmarshes were amongst the least valuable habitats for all bee types. Under appropriate grazing management, saltmarshes provide a valuable and previously overlooked foraging habitat for bees. The strong effects of livestock grazing identified here are likely to extend geographically given that both livestock grazing and key grazing-sensitive plants are widespread in European saltmarshes. We recommend that long-term ungrazed saltmarshes are protected from grazing, and that grazing is maintained at extensive levels on grazed marshes. In this way, saltmarshes can provide forage for wild and managed bee populations and support ecosystem services

A Propensity for n-omega-Amino Acids in Thermally-Altered Antarctic Meteorites

Carbonaceous meteorites are known to contain a wealth of indigenous organic molecules, including amino acids, which suggests that these meteorites could have been an important source of prebiotic organic material during the origins of life on Earth and possibly elsewhere. We report the detection of extraterrestrial amino acids in thermally-altered type 3 CV and CO carbonaceous chondrites and ureilites recovered from Antarctica. The amino acid concentrations of the thirteen Antarctic meteorites were generally less abundant than in more amino acid-rich CI, CM, and CR carbonaceous chondrites that experienced much lower temperature aqueous alteration on their parent bodies. In contrast to low-temperature aqueously-altered meteorites that show complete structural diversity in amino acids formed predominantly by Strecker-cyanohydrin synthesis, the thermally-altered meteorites studied here are dominated by small, straight-chain, amine terminal (n-omega-amino) amino acids that are not consistent with Strecker formation. The carbon isotopic ratios of two extraterrestrial n-omega-amino acids measured in one of the CV chondrites are consistent with C-13-depletions observed previously in hydrocarbons produced by Fischer-Tropsch type reactions. The predominance of n-omega-amino acid isomers in thermally-altered meteorites hints at cosmochemical mechanisms for the preferential formation and preservation of a small subset of the possible amino acids

How low can SUSY go? Matching, monojets and compressed spectra

If supersymmetry (SUSY) has a compressed spectrum then the current mass limits from the LHC can be drastically reduced. We consider a possible 'worst case' scenario where the gluino and/or squarks are degenerate with the lightest SUSY particle (LSP). The most sensitive searches for these compressed spectra are via the final state LSPs recoiling against initial state radiation (ISR). Therefore it is vital that the ISR is understood and possible uncertainties in the predictions are evaluated. We use both MLM (with Pythia 6) and CKKW- L (with Pythia 8) matching and vary matching scales and parton shower properties to accurately determine the theoretical uncertainties in the kinematic distributions. All current LHC SUSY and monojet analyses are employed and we find the most constraining limits come from the CMS Razor and CMS monojet searches. For a scenario of squarks degenerate with the LSP and decoupled gluinos we find $M_{\tilde{q}}>340$ GeV. For gluinos degenerate with the LSP and decoupled squarks, $M_{\tilde{g}}>500$ GeV. For equal mass squarks and gluinos degenerate with the LSP, $M_{\tilde{q},\tilde{g}}>650$ GeV.Comment: References added, version submitted to ep

Halogen effects on the solid-state packing of phenylalanine derivatives and the resultant gelation properties

Phenylalanine is an important amino acid both biologically, essential to human health, and industrially, as a building block of artificial sweeteners. Our interest in this particular amino acid and its derivatives lies with its ability to form gels in a number of solvents. We present here the studies of the influence of halogen addition to the aromatic ring on the gelation properties and we analyse the crystal structures of a number of these materials to elucidate the trends in their behaviour based on the halogen addition to the aromatic group and the interactions that result

Distribution of Metals in the Termite Tumulitermes tumuli (Froggatt): Two Types of Malpighian Tubule Concretion Host Zn and Ca Mutually Exclusively

The aim of this study was to determine specific distribution of metals in the termite Tumulitermes tumuli (Froggatt) and identify specific organs within the termite that host elevated metals and therefore play an important role in the regulation and transfer of these back into the environment. Like other insects, termites bio-accumulate essential metals to reinforce cuticular structures and utilize storage detoxification for other metals including Ca, P, Mg and K. Previously, Mn and Zn have been found concentrated in mandible tips and are associated with increased hardness whereas Ca, P, Mg and K are accumulated in Malpighian tubules. Using high resolution Particle Induced X-Ray Emission (PIXE) mapping of whole termites and Scanning Electron Microscope (SEM) Energy Dispersive X-ray (EDX) spot analysis, localised accumulations of metals in the termite T. tumuli were identified. Tumulitermes tumuli was found to have proportionally high Mn concentrations in mandible tips. Malpighian tubules had significant enrichment of Zn (1.6%), Mg (4.9%), P (6.8%), Ca (2.7%) and K (2.4%). Synchrotron scanning X-ray Fluorescence Microprobe (XFM) mapping demonstrated two different concretion types defined by the mutually exclusive presence of Ca and Zn. In-situ SEM EDX realisation of these concretions is problematic due to the excitation volume caused by operating conditions required to detect minor amounts of Zn in the presence of significant amounts of Na. For this reason, previous researchers have not demonstrated this surprising finding