Winding Back Wayfair : Retaining the Physical Presence Rule for State Income Taxation

In 2018, the U.S. Supreme Court decided South Dakota v. Wayfair, Inc., a case abrogating the physical presence rule from Quill Corp. v. North Dakota. The physical presence rule barred a state from forcing a retailer to collect sales taxes on the state\u27s behalf if the retailer lacked a physical presence within the state. The decision came after a decades-long effort by the states to reach sales-tax revenue effectively pushed beyond their reach by the physical presence rule. While enabling states to reach a new revenue source, the Court failed to take full account of the reliance interests dependent on the physical presence rule. In particular, the Court did not consider the effect its decision would have on businesses that used the physical presence rule as a shield from state income-tax liability. Thus, the Court erred in abrogating the physical presence rule without considering the full picture. This Note argues that Congress should pass legislation reinstating the physical presence rule for income-tax purposes to ensure that the Wayfair decision will not result in an unanticipated disruption in commerce

WT2 : a low budget experiment in“heart, humour and horror"

In 1999, the London-based production company, Working Title Films, established a subsidiary called WT2 which was given the remit of producing low-budget films. Between 2000 and 2007, WT2 released 10 feature films including Billy Elliot (2000), Ali G Indahouse (2002) and Long Time Dead (2002) which respectively exemplified the company’s creative agenda of ‘the three Hs’, that is, ‘heart, humour and horror’. This article examines the creative and commercial contexts of filmmaking at play within WT2 and, in turn, considers the company’s position within Working Title and between its major financiers, StudioCanal and Universal. In doing so, I argue that WT2’s films occupy a position between the filmmaking industries and cultures of Europe and Hollywood which is distinct from that of its parent company. On the one hand, a number of WT2’s films engage with established trends in low-budget British cinema including social realism and the adaptation of television comedy, and were co-produced by British broadcasters, national film agencies and independent production companies. On the other, these films were largely financed, distributed and marketed by multinational media conglomerates with commercial agendas and transnational or global reaches. Thus, this article examines the ways in which the tension between the national and the transnational was played out in both the company’s operation and output

Characterisation and description of compressible rubbery materials for component modelling

Rubbery foams and similar highly compressible rubbery solids form an important class of materials for technology. In order for components made from such materials to be modelled, in Finite Element Analysis (FEA) for example, appropriate constitutive laws are required.The review of the literature revealed that rubbery foams lacked the array of comprehensive data sets that have been published for near-incompressible rubbery materials for example. Moreover there were important contradictions between accounts of how rubbery foams behaved at finite strains. The review of the literature also raised some doubts on what the value of Poisson’s ratio (ν) should be for such materials in simple extension – let alone in compression.Most finite strain FEA of rubbery foams seems to use in the constitutive law a finite strain version of ν based on logarithmic strains: here called the Poisson index, υ. Some of the implications of such approaches have been explored via theory and experiments. Some doubt has thereby been cast on such approaches.In this project experiments performed in simple compression on a normal natural rubber latex foam have confirmed that the apparent Poisson ratio can fall to very low values even at rather small strains; the apparent Young modulus can drop to low values even at very small strains. The experiments have also indicated that: ν, and therefore υ at small strain simple extension, can be well below the value of 1/3 usually assumed; the value of υ can rise as extension progresses and can exceed ½

PolyGram Filmed Entertainment and Working Title Films: The Making of a Film Studio and its Production Label

In the 1990s, the London-based production company, Working Title Films, become synonymous with a brand of globally oriented popular cinema which is identifiably British in content while also embracing many of the aesthetic and cultural forms of Hollywood filmmaking. Notable films include Four Weddings and a Funeral (1994), Bean (1997), The Borrowers (1997) and Notting Hill (1999). This paper examines the origins of this production strategy between 1988 and 1993. During these six years, Working Title was transformed from an independently owned and managed production company which largely produced Channel 4-funded ‘social art cinema’ to a subsidiary label of the nascent film studio, PolyGram Filmed Entertainment (PFE). Taking the approach of business history, I will explore PFE’s key innovations, particularly the development of the so-called ‘control sheet’, a creative and commercial filter used to inform green-light decisions. In so doing, a complex and dynamic picture of filmmaking within a newly formed studio system emerges. Significantly, control sheet-like business practices were also adopted by the major Hollywood studios. Thus, the logic of the control sheet continues to underpin the current media ecology of Hollywood at large, including that of Working Title’s current parent company, Universal

IR Dynamics on Branes and Space-Time Geometry

We consider the type I theory compactified on $T^3$. When the D5-brane wraps the $T^3$ it yields a D2-brane in seven dimensions. In the leading approximation the moduli space of vacua of the three dimensional field theory on the brane is T^4/\ZZ_2. The dual M theory description of this theory is a compactification on K3 and our 2-brane is the eleven dimensional 2-brane at a point in K3. We use this fact to conclude that strong coupling IR effects in the three dimensional theory on the brane turn its moduli space into a K3. This interpretation allows us to solve various strongly coupled gauge theories in three dimensions by identifying their Coulomb branch with a piece of a (sometime singular) K3.Comment: 8 pages, uses harvmac, one reference adde

Phylogenetic Patterns in Montane Troglodytes Wrens

Phylogenetic studies based on mitochondrial DNA sequences of 10 species of wrens in Troglodytes and related genera suggest a new hypothesis of relationships for the group. The Winter Wren (T. troglodytes) and the anomalous Timberline Wren (Thryorchilus browni) are distantly related to the remainder of Troglodytes. The latter group divides into a tropical montane group and a northern/lowland group that includes the northernmost two montane taxa (T. rufociliatus, T. brunneicollis). Erection of the genus Nannus for the Winter Wren is proposed. Song evolution in the complex has involved either convergent derivation or retention of primitive song types in distant lineages

Influence of biological variations and sample handling on measured microalbuminuria in diabetic patients

Five immunochemical assays for determining low concentrations of albumin were investigated. These were a radioimmunoassay (RIA); turbidimetric immunoassays (TIA) both according to end-point measuring principle on a Cobas Fara and Hitachi 717 analysers, and according to kinetic measuring principle on a Turbitimer instrument; and a nephelometric immunoassay (NIA). All achieved the analytical goal necessary for optimal patient care. The correlations between the albumin concentrations measured with the different techniques were very good. In vitro glycation of albumin did not influence albumin concentrations measured by the five assays. Urine albumin excretion measured over 3 consecutie days showed considerable day-to-day variation. This was highest for spot-urine specimens and significantly lower for 24 h and timed-overnight samples. Variation of storage temperature (room temperature, 4°C, -20°C), time (up till 3 months), and pH (within the range pH 5-8) of the urine samples did not change significantly the measured albumin concentrations. Different sample preparations (vortex-mixing, centrifugation, and thawing) had no influence on the measured albumin concentration. In conclusion, a maximum standardization of the collection of timed-overnight urine samples for screening and 24 h urine sampels for confirmation of microalbuminuria during 3 consecutive days is more crucial than the choice of the immunological technique

Update on Radiation Dose From Galactic and Solar Protons at the Moon Using the LRO/CRaTER Microdosimeter

The NASA Lunar Reconnaissance Orbiter (LRO) has been exploring the lunar surface and radiation environment since June 2009. In Mazur et al. [2011] we discussed the first 6 months of mission data from a microdosimeter that is housed within the Cosmic Ray Telescope for the Effects of Radiation (CRaTER) instrument onboard LRO. The CRaTER microdosimeter is an early version of what is now a commercially available hybrid that accurately measures total ionizing radiation dose in a silicon target (http://www.teledynemicro.com/product/radiation-dosimeter). This brief report updates the transition from a deep solar minimum radiation environment to the current weak solar maximum as witnessed with the microdosimeter

Notes on Theories with 16 Supercharges

We survey the various field theories with 16 real supercharges. The most widely known theory in this class is the N=4 theory in four dimensions. The moduli space of vacua of these theories are described and the physics at the singularities of the moduli spaces are studied.Comment: This is an updated version of lectures presented at the Jerusalem Winter School on Strings and Duality. These notes will appear in the Proceedings of The Trieste Spring School (March 7--12). 22 pages (harvmac). Typos and references correcte

Effect of Block Design on Swimming Relay Start Performance

Starting blocks used in competitive swimming often incorporate a wedge for the rear foot to push against when performing flat starts. In most competitions, this wedge cannot be removed so relay starts must be performed with the wedge in place despite the common addition of an approach step during a relay starts. The presence of the wedge constrains the length of the approach step but does provide an inclined surface from which to push which may improve propulsive force development. PURPOSE: The purpose of this study was to evaluate the effect of using a wedge in relay start performance. METHODS: Eight collegiate swimmers (177.69 + 8.73 cm, 74.7 + 9.11 kg, 19.59 + 0.59 years) provided informed consent and completed eight maximal effort relay starts, four with the wedge in place and four without. For all starts, participants were instructed to maintain a streamline position upon entering the water and to glide as far as possible. A relay judging platform was installed on the block and used with an in-water touch pad to measure the exchange time for the relay start. Two synchronized cameras captured movements at 60 Hz above and below water. A 16-point model of the body was used to compute center of mass position for above water movements. Takeoff velocity and angle were defined using the horizontal and vertical velocity of the whole body center of mass. Time to 7m was measured as the time needed for the wrist to reach a point 7m from the pool wall. Paired t-tests were used to compare dependent measures between start conditions. RESULTS: Exchange time (t(7) = 0.11, p = 0.99), takeoff angle (t(7)= 0.60, p = 0.57), and time to 7 m (t(7) = 0.69, p = 0.51) were not different when using the wedge as compared to not using the wedge (Table 1). However, takeoff velocity without the wedge was 2.4% faster (t(7) = 2.48, p = 0.04) than with the wedge on the block (p\u3c0.05). This difference was characterized by a moderate effect size (Cohen d = 0.46). CONCLUSION: Presence of the wedge on the block had a minimal effect on relay start performance. It adversely affected start performance by decreasing takeoff velocity however no other kinematic variables were affected. Having the wedge on the block may constrain the step length of the swimmer during the relay start, which might explain the decrease in velocity