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

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 II 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