Reforming 501(c)(3): Putting the Charity Back in the Charitable Deduction

This paper seeks to lay out a proposal to redefine what it takes to receive tax-deductible donations. Part H of this paper will summarize the current state of the law as it applies to the charitable contribution deduction and the qualification for tax exemption under the Internal Revenue Code. Part III discusses the Charities Act 2006, a recent British act aimed at attempting to redefine charity for England and Wales by requiring organizations to prove that they provide a public benefit before receiving the benefits of being a charity. Part IV proposes additions and changes to the Internal Revenue Code which, if implemented, would redefine the requirements for an organization to receive tax-deductible contributions based on their ability to provide for the public benefit. Finally, this paper concludes that change is needed to ensure that only those organizations providing sufficient public benefits are receiving tax-deductible contributions

Reforming 501(c)(3): Putting the Charity Back in the Charitable Deduction

This paper seeks to lay out a proposal to redefine what it takes to receive tax-deductible donations. Part H of this paper will summarize the current state of the law as it applies to the charitable contribution deduction and the qualification for tax exemption under the Internal Revenue Code. Part III discusses the Charities Act 2006, a recent British act aimed at attempting to redefine charity for England and Wales by requiring organizations to prove that they provide a public benefit before receiving the benefits of being a charity. Part IV proposes additions and changes to the Internal Revenue Code which, if implemented, would redefine the requirements for an organization to receive tax-deductible contributions based on their ability to provide for the public benefit. Finally, this paper concludes that change is needed to ensure that only those organizations providing sufficient public benefits are receiving tax-deductible contributions

Inclusive-PIM: Hardware-Software Co-design for Broad Acceleration on Commercial PIM Architectures

Continual demand for memory bandwidth has made it worthwhile for memory vendors to reassess processing in memory (PIM), which enables higher bandwidth by placing compute units in/near-memory. As such, memory vendors have recently proposed commercially viable PIM designs. However, these proposals are largely driven by the needs of (a narrow set of) machine learning (ML) primitives. While such proposals are reasonable given the the growing importance of ML, as memory is a pervasive component, %in this work, we make there is a case for a more inclusive PIM design that can accelerate primitives across domains. In this work, we ascertain the capabilities of commercial PIM proposals to accelerate various primitives across domains. We first begin with outlining a set of characteristics, termed PIM-amenability-test, which aid in assessing if a given primitive is likely to be accelerated by PIM. Next, we apply this test to primitives under study to ascertain efficient data-placement and orchestration to map the primitives to underlying PIM architecture. We observe here that, even though primitives under study are largely PIM-amenable, existing commercial PIM proposals do not realize their performance potential for these primitives. To address this, we identify bottlenecks that arise in PIM execution and propose hardware and software optimizations which stand to broaden the acceleration reach of commercial PIM designs (improving average PIM speedups from 1.12x to 2.49x relative to a GPU baseline). Overall, while we believe emerging commercial PIM proposals add a necessary and complementary design point in the application acceleration space, hardware-software co-design is necessary to deliver their benefits broadly

Current Distribution for the Metallization of Resistive Wafer Substrates under Controlled Geometric Variations

Current distribution simulation results are presented for the metallizaton of 200-mm resistive wafer substrates. A novel horizontal plating cell design that features an insulating hole and a wafer holder that is capable of varying the wafer position vertically during the metallization process is considered to improve the current distribution across the wafer substrate surface. Numerical analysis is used to investigate the influence of the insulating hole size, wafer position, and wafer movement during the deposition process on the current distribution and is compared to experimental data for copper deposition when possible. Submicrometer scale multilevel metallization is one of the key technologies for the next generation of ultralarge-scale integration

An online intervention for improving stroke survivors' health-related quality of life : study protocol for a randomised controlled trial

Background: Recurrent stroke is a major contributor to stroke-related disability and costs. Improving health-risk behaviours and mental health has the potential to significantly improve recovery, enhance health-related quality of life (HRQoL), independent living, and lower the risk of recurrent stroke. The primary aim will be to test the effectiveness of an online intervention to improve HRQoL among stroke survivors at 6 months' follow-up. Programme effectiveness on four health behaviours, anxiety and depression, cost-effectiveness, and impact on other hospital admissions will also be assessed. Methods/design: An open-label randomised controlled trial is planned. A total of 530 adults will be recruited across one national and one regional stroke registry and block randomised to the intervention or minimal care control group. The intervention group will receive access to the online programme Prevent 2nd Stroke (P2S); the minimal care control group will receive an email with Internet addresses of generic health sites designed for the general population. The primary outcome, HRQoL, will be measured using the EuroQol-5D. A full analysis plan will compare between groups from baseline to follow-up. Discussion: A low-cost per user option to supplement current care, such as P2S, has the potential to increase HRQoL for stroke survivors, and reduce the risk of second stroke

Barriers and facilitators influencing the sustainment of health behaviour interventions in schools and childcare services: a systematic review

Background Sustainment has been defined as the sustained use or delivery of an intervention in practice following cessation of external implementation support. This review aimed to identify and synthesise factors (barriers and facilitators) that influence the sustainment of interventions (policies, practices, or programmes) in schools and childcare services that address the leading risk factors of chronic disease. Methods Seven electronic databases and relevant reference lists were searched for articles, of any design, published in English, from inception to March 2020. Articles were included if they qualitatively and/or quantitatively reported on school or childcare stakeholders’ (including teachers, principals, administrators, or managers) perceived barriers or facilitators to the sustainment of interventions addressing poor diet/nutrition, physical inactivity, obesity, tobacco smoking, or harmful alcohol use. Two independent reviewers screened texts, and extracted and coded data guided by the Integrated Sustainability Framework, an existing multi-level sustainability-specific framework that assesses factors of sustainment. Results Of the 13,158 articles identified, 31 articles met the inclusion criteria (8 quantitative, 12 qualitative, 10 mixed-methods, and 1 summary article). Overall, 29 articles were undertaken in schools (elementary n=17, middle n=3, secondary n=4, or a combination n=5) and two in childcare settings. The main health behaviours targeted included physical activity (n=9), diet (n=3), both diet and physical activity (n=15), and smoking (n=4), either independently (n=1) or combined with other health behaviours (n=3). Findings suggest that the majority of the 59 barriers and 74 facilitators identified to impact on intervention sustainment were similar across school and childcare settings. Factors predominantly relating to the ‘inner contextual factors’ of the organisation including: availability of facilities or equipment, continued executive or leadership support present, and team cohesion, support, or teamwork were perceived by stakeholders as influential to intervention sustainment. Conclusions Identifying strategies to improve the sustainment of health behaviour interventions in these settings requires a comprehensive understanding of factors that may impede or promote their ongoing delivery. This review identified multi-level factors that can be addressed by strategies to improve the sustainment of such interventions, and suggests how future research might address gaps in the evidence base. Trial registration This review was prospectively registered on PROSPERO: CRD42020127869 , Jan. 2020

Placental size and foetal growth in relation to maternal undernutrition during mid-pregnancy in sheep

Examination of the evidence published in the literature revealed a variety of responses in birth weight of the lamb to maternal undernutrition during mid pregnancy. Explanations of the various responses are commonly made in terms of what has been named, in this thesis, as the Size Hypothesis. This hypothesis states that placental size is limiting the transfer of nutrients across the placenta during late pregnancy, and therefore determining foetal growth. The two main assumptions of this hypothesis are that (i) placental size is an index of its maximum functional capacity, and.(ii) the placenta is functioning at its maximum capacity during late pregnancy. In this thesis the validity of both of these assumptions is questioned, and, an alternative hypothesis proposed. Chapter One reviews the factors which are involved in the movement of metabolic substrate from the dam, across the placental barrier and to the site(s) of deposition in the foetus. From the limited amount of information available in the literature, it is apparent that placental size is not necessarily an accurate indicator of the maximum functional capacity of the placenta. Therefore the Size Hypothesis cannot be functionally correct. Consideration of the evidence used to support the Size Hypothesis questioned the causal relationship between placental size, and growth of the foetus during late pregnancy. Consequently experiments were designed to: (i)investigate the effect of maternal undernutrition during mid pregnancy on placental size. (ii)determine the functional relationship between placental size and foetal growth. Maternal undernutrition during mid pregnancy was chosen as the means of manipulation of placental size because of its direct relevance to the extensive grazing system of sheep management in Southern Australia. In the first experiment (Chapter Two) maternal undernutrition imposed between 75 and 100 days post coitus tended (P=0.08) to reduce both placental size, measured at 100 days post coitus, and weight of the lamb at birth. The relationship between placental size and growth of the foetus remained unresolved. Therefore a second experiment was designed. In this experiment (Chapter Three) single bearing pregnant ewes were exposed to undernutrition during one of three periods during mid pregnancy; 30 to 96 days (Group RA), 50 to 96 days (Group RB) and 75 to 96 days (Group RC) post coitus. Placental growth was retarded in ewes exposed to maternal undernutrition between 30 and 96 days post coitus, while the shorter periods of undernutrition had no significant effect on placental growth. Despite a smaller maximum placental size being achieved for group RA compared to control (well fed) ewes, and all ewes being fed on a high plane of nutrition during late pregnancy, foetal growth during late pregnancy was not significantly different between group RA and control (well fed) This evidence supports the hypothesis that placental size per se is not the prime determinant of foetal growth. The effect of altering placental size, by maternal undernutrition between the time of conception and 70 days post coitus (Chapter Four), or the number of foetuses sharing one uterus (Chapter Four, Chapter Five), on birth weight of the lamb was investigated. One experiment in Chapter Four (Experiment One) twin lambs at birth were not significantly lighter in weight, despite being associated with a smaller placenta, when compared to the single lambs. This is further evidence to suggest that placental size per se was not limiting growth of the foetus during late pregnancy. The final two experimental chapters in this thesis quantify the relationship between placental size and some functional aspects of the placenta. Placental size was not closely related to either the volume of blood in the placenta (Chapter Six), or the rate of movement of calcium (Chapter Seven) across the placenta. All experiments discuss the possible sites of limitation, or regulation, to the movement of nutrients to the foetus. These include the regulation of the intake of feed, the digestion, metabolism and partition of the metabolic substrates in the dam as they influence growth of the foetus. The experiments in this thesis demonstrated that growth of the placenta can be improved, retarded or remain unaffected by maternal undernutrition being imposed at various times during the first 100 days post coitus. Explanation of the potential effect which nutritional stress has in altering placental growth, is often made in terms of the degree to which the mobilization of maternal body reserves may buffer the conceptus from any nutrient limitation on growth of the foetus. In contrast to this, the experiment described in Chapter Seven reported that growth of the placenta, in ewes fed at a restricted level of nutrition, was greater when compared with their control (well fed) counterparts. The factors causing this stimulation in placenta growth are yet to be identified. Regression analysis of data from all experiments revealed that both placental size near parturition (P<0.001), and the change in liveweight during the period of nutritional restriction (P=0.06), were related to weight of the foetus near parturition. Conversely the liveweight and/or condition score of the dam at the time of joining was not related to placental size or foetal weight near parturition. This observation suggested that the level of body reserves at the time of joining does not significantly modify the effect which maternal undernutrition has. on placental and foetal growth. Maternal undernutrition during the first 100 days post coitus had little or no effect on growth of the foetus, measured at the end of the restriction period, despite a significant depletion in the body reserves of the dam. In addition, the large differences in the patterns of placental growth caused by maternal feed restriction were not reflected in weight of the lamb at birth. Differences in voluntary food intake and the level of body reserves available for mobilization/deposition, between the previously restricted and control (well fed) ewes, were not reflected in the whole-body metabolism of either glucose or calcium (Chapter Seven). Therefore the Size Hypothesis was not confirmed by the observations made in this thesis. Evidence used to support the Size Hypothesis includes the observation that the rate of foetal growth during late pregnancy does not continue to increase at an increasing rate, even when the ewe is well fed during late pregnancy. It has been proposed by other workers (e.g. Mellor, 1983) that this indicates that the functional capacity of the placenta is limiting foetal growth. The experiment reported in Chapter Three demonstrated that, despite a retardation in placental size of as much as 23 percent by 96 days post coitus, growth of the foetus during the final 12 days of pregnancy was similar for both the control (well fed) and previously under fed (restricted) ewes. It was therefore concluded that placental size per se cannot be limiting foetal growth during late pregnancy. In another experiment (Chapter Seven) maternal undernutrition during mid pregnancy resulted in an increase in placental growth of 21 percent, despite the ewes being severely under fed between 30 and 96 days post coitus. The rate of transport of calcium across the placenta, and its lack of any relationship to placental size, indicated that placental size was not an appropriate indicator of its movement. In contrast to the prediction of the Size Hypothesis, foetal growth during late pregnancy was not improved despite the ewes being fed on a high plane of nutrition during the period between 96 days post coitus and the time of parturition. The circumstances in which a relationship between "size" and "function" were strong, and those in which no close relationship existed, were examined in an attempt to define the physiological conditions regulating foetal growth. An alternative hypothesis, termed the Functional Reserve Hypothesis was proposed. It aims to incorporate all available observations made in the experimental work reported in this thesis, and from the relevant literature reported elsewhere. The concept central to Functional Reserve Hypothesis is that the ovine placenta is not in a state of functional saturation during late pregnancy, and hence does not act as a limitation to growth of the foetus. In addition, the Functional Reserve Hypothesis proposes that placental size is not an accurate indicator of the capacity of the placenta to transfer nutrients. It is hypothesized that the ovine placenta has same level of functional reserve, even in the situations where it is retarded in its growth. Additionally it is proposed that factors regulating both (i) the partition and supply of nutrients from the dam, and (ii) the potential for growth, and the demand for nutrients by the foetus, all interact to regulate the rate of' foetal growth during late pregnancy and therefore ultimately the birth weight of the lamb. Before successful manipulation of foetal growth during late pregnancy is possible, the key metabolic substrates, and the factors regulating their movement to the foetus, need to be identified. Finally, how the above results contribute to the development of strategic feeding recommendations for the Australian sheep flock are discussed. Two specific areas for further research are identified