The Thirteenth Amendment and the Hate Crimes Prevention Act: Is There Room for Religion?

40 pages.This Comment explores the extent to which federal hate crime legislation such as the Hate Crimes Prevention Act (HCPA) protects people from bias-motivated violence on account of their religion. In doing so, it examines racial and religious protection in the context of Thirteenth Amendment jurisprudence and federal hate crime legislation. This Comment seeks to explain and clarify the relationship between the Thirteenth Amendment, religion, and federal hate crime statutes like the HCPA

The Rules of the Fight Must be Fair: States Should Pass a Uniform Code for Nonprofit Hospital Tax Exemption of Real Property

The lines have been blurred between a charitable hospital and a profit-generating healthcare business. The definition of charitable care has been under pressure from government taxing authorities seeking to raise tax revenues by challenging the tax exemption for vast amounts of hospital real estate. Charitable hospitals are pushing to expand the definition of charitable care, while at the same time seeking tax exemption for a growing number of satellite properties. This conflict between governments and hospitals is leading to confusion about what qualifies as charity care, warranting nonprofit status, and the privilege of tax exemption. Local taxing authorities, state courts, and nonprofit hospitals all need a clear codified standard for charitable care to differentiate between medical facilities that ought to qualify for an exemption from real property tax and those that should not

In vivo effect of FK506 on human pancreatic islets

The purpose of this study was to evaluate the in vivo effect of FK506 on human pancreatic islets. Twenty-five nude mice were made diabetic by one intravenous injection of streptozotocin. Approximately 600 islets were administered in the renal subcapsular space 3-5 days following streptozotocin administration. One week after transplantation, the mice were divided in four groups. In group 1, the animals received 1 injection of 0.5 ml of diluent i.p. daily for one week. In groups 2, 3, and 4 the treatments were daily i.p. injection of 0.3, 1, and 3 mg/kg FK506, respectively. After treatment, the functional integrity of the transplanted human islets was tested by measuring the plasma glucose and human C-peptide response to intraperitoneal glucose injection in groups 1 and 4. IPGTT alone was assessed in groups 2 and 3. The results indicate that i.p. administration of FK506 for one week at a dose 0.3 mg/kg/day did not result in any significant alteration of glucose disappearance and C-peptide response to IPGTT. Higher doses of FK506 produced a significant delay in glucose disappearance in groups 3 and 4, and a significant inhibition of glucose-mediated C-peptide response in group 4. © 1991 by Williams and Wilkins

Not Just for Americans: The Case for Expanding Reciprocal Tax Exemptions for Foreign Investments by Pension Funds

From provision of OAS, GIS and CPP to the favourable taxation of Registered Pension Plans and RRSPs , Canada’s government has long focused policy efforts on better ensuring that working Canadians approach retirement with sufficient income supports in place. If the government wants to continue to move in this direction by trying to help maximize returns to pension plan members, while decreasing the portfolio risks faced by those pension plans, one step it could consider would be: Expanding the exemption for withholding taxes on foreign dividends and interest earned by pension plans. The exemptions for foreign interest and dividends are already available to U.S. investments, part of a reciprocal arrangement spelled out in the Canada-U.S. Tax Convention. Those exemptions allow U.S. and Canadian pension funds to participate in cross-border investments that would otherwise be too costly. Pension funds rely on international investments to optimize diversification and returns. And tax conventions between countries are typically designed to protect investors from the participating countries from being double taxed by both their resident country and the foreign jurisdiction where they invest. This good policy has certainly been Canada’s model in its numerous bilateral tax treaties. But while the U.S.-Canada Tax Convention extends the benefit of tax exemption to dividends and interest earned from cross-border investments by tax-exempt pension funds, when it comes to all other countries, there is no equivalent result. Yet, aspects of these same exemptions exist in certain bilateral treaties between other countries in treaties with one another. That certainly suggests that there are other trading partners, besides just the U.S., that are open to the possibility of these particular exemptions. If Canada could negotiate broadening these exemptions to countries beyond the United States, it would realize important advantages with little cost. By not moving further in this direction for non-U.S. foreign interest and dividend income of Canadian pension funds, these funds are left with lower benefits or higher contribution rates for pension plan members. It is also inevitably distorting the investment decisions being made by pension fund managers, producing a negative impact on risk-adjusted returns to their portfolios. While Canada may lose some revenue by forsaking some withholding tax, that would almost certainly be outweighed by the total economic gains as pension returns increase and, in reciprocal arrangements, Canada becomes more welcoming to foreign capital. With a number of countries already evidently open to the idea of tax exemptions for foreign interest and dividends earned by pension funds, and the economic effects for doing so overwhelmingly positive, the Canadian government should seriously consider getting started on negotiating reciprocal arrangements for cross-border pension fund investment with other countries

Pancreatic islet transplantation after upper abdominal exeriteration and liver replacement

Nine patients who became diabetic after upper-abdominal exenteration and liver transplantation were given pancreatic islet-cell grafts obtained from the liver donor (eight cases), a third-party donor (one), or both (four). Two patients were diabetic when they died of infections after 48 and 109 days, as was a third patient who died of tumour recurrence after 178 days. The other 6 are alive 101-186 days postoperatively, and five are insulin-free or on insulin only during night-time parenteral alimentation. C-peptide increased 1·7 to 3·3 fold in response to intravenous glucose in these five patients who have had glycosylated haemoglobin in the high normal range. However, the kinetics of the C-peptide responses to intravenous glucose in all eight patients tested revealed an absent first-phase release and a delayed peak response consistent with transplantation and/or engraftment of a suboptimal islet cell mass. The longest survivor, who requires neither parenteral alimentation nor insulin, is the first unequivocal example of successful clinical islet-cell transplantation. © 1990

Human islet isolation and allotransplantation in 22 consecutive cases

This report provides our initial experience in islet isolation and intrahepatic allotransplantation in 21 patients. In group 1, 10 patients underwent combined liver-islet allotransplantation following upper-abdominal exenteration for cancer. In group 2, 4 patients received a combined liver-islet allograft for cirrhosis and diabetes. One patient had plasma C-peptide >3 pM and was therefore excluded from analysis. In group 3, 7 patients received 8 combined cadaveric kidney-islet grafts (one retransplant) for end-stage renal disease secondary to type 1 diabetes mellitus. The islets were separated by a modification of the automated method for human islet isolation and the preparations were infused into the portal vein. Immunosuppression was with FK506 (group 1) plus steroids (groups 2 and 3). Six patients in group 1 did not require insulin treatment for 5 to > 16 months. In groups 2 and 3 none of the patients became insulin-independent, although decreased insulin requirement and stabilization of diabetes were observed. Our results indicate that rejection is still a major factor limiting the clinical application of islet transplantation in patients with type 1 diabetes mellitus, although other factors such as steroid treatment may contribute to deteriorate islet engraftment and/or function. © 1992 by Williams and Wilkins