Quest for Cash: Exempt Organizations, Joint Ventures, Taxable Subsidiaries, and Unrelated Business Income

Most “for-profit” or “business” activities of exempt organizations take one of three forms: (A) The exempt organization may undertake to perform the business activities within the existing structure of the exempt organization. (B) The exempt organization may form a “taxable” subsidiary or affiliate which will perform the business activities. (C) The exempt organization may “partner” with other individuals and entities (both nonprofit and for-profit) to form a corporation, limited liability company (LLC), partnership, joint venture, strategic alliance, or other collaborative effort which will perform the “for-profit” activities. Depending in part upon which of these forms is chosen, any business activities by an exempt organization may result in: (i) income taxes being imposed upon the exempt organization or the “for-profit” entity; (ii) the exempt organization losing its tax-exempt status; (iii) excise taxes being imposed by the Internal Revenue Service (IRS) on the individuals and for-profit companies (as well as on the managers of the exempt organization) with whom the tax-exempt organization conducts a business activity; (iv) a regulatory action brought against the organization by federal or state governmental authorities; or (v) all of the above. This article gives an overview of the regulations, Treasury rulings, IRS manuals, and case law that become important when an exempt organization decides to engage in business activity

Quest for Cash: Exempt Organizations, Joint Ventures, Taxable Subsidiaries, and Unrelated Business Income

Most “for-profit” or “business” activities of exempt organizations take one of three forms: (A) The exempt organization may undertake to perform the business activities within the existing structure of the exempt organization. (B) The exempt organization may form a “taxable” subsidiary or affiliate which will perform the business activities. (C) The exempt organization may “partner” with other individuals and entities (both nonprofit and for-profit) to form a corporation, limited liability company (LLC), partnership, joint venture, strategic alliance, or other collaborative effort which will perform the “for-profit” activities. Depending in part upon which of these forms is chosen, any business activities by an exempt organization may result in: (i) income taxes being imposed upon the exempt organization or the “for-profit” entity; (ii) the exempt organization losing its tax-exempt status; (iii) excise taxes being imposed by the Internal Revenue Service (IRS) on the individuals and for-profit companies (as well as on the managers of the exempt organization) with whom the tax-exempt organization conducts a business activity; (iv) a regulatory action brought against the organization by federal or state governmental authorities; or (v) all of the above. This article gives an overview of the regulations, Treasury rulings, IRS manuals, and case law that become important when an exempt organization decides to engage in business activity

Shapes of Knotted Cyclic Polymers(Knots and soft-matter physics: Topology of polymers and related topics in physics, mathematics and biology)

この論文は国立情報学研究所の電子図書館事業により電子化されました。Momentary configurations of long polymers at thermal equilibrium usually deviate from spherical symmetry and can be better described, on average, by a prolate ellipsoid. The asphericity and nature of asphericity (or prolateness) that describe these momentary ellipsoidal shapes of a polymer are determined by specific expressions involving the three principal moments of inertia calculated for configurations of the polymer. Earlier theoretical studies and numerical simulations have established that as the length of the polymer increases, the average shape for the statistical ensemble of random configurations asymptotically approaches a characteristic universal shape that depends on the solvent quality. It has been established, however, that these universal shapes differ for linear, circular, and branched chains. We investigate here the effect of knotting on the shape of cyclic polymers modeled as random isosegmental polygons. We observe that random polygons forming different knot types reach asymptotic shapes that are distinct from the ensemble average shape. For the same chain length, more complex knots are, on average, more spherical than less complex knots. This paper is a shorter, revised version of the article Ref. [12]. For more details, see Ref. [12]

Functional skewing of the global CD8 T cell population in chronic hepatitis B virus infection

The inflamed liver in chronic hepatitis B virus (HBV) infection (CHB) is characterized by a large influx of non–virus-specific CD8 T cells. Little is known about the functional capacity of these lymphocytes, which could provide insights into mechanisms of failure of viral control and liver damage in this setting. We compared the effector function of total circulating and intrahepatic CD8 T cells in CHB patients and healthy donors. We demonstrated that CD8 T cells from CHB patients, regardless of their antigen specificity, were impaired in their ability to produce interleukin-2 and proliferate upon TCR-dependent stimulation. In contrast, these CD8 T cells had preserved production of the proinflammatory cytokines interferon-γ and tumor necrosis factor-α. This aberrant functional profile was partially attributable to down-regulation of the proximal T cell receptor signaling molecule CD3ζ, and could be corrected in vitro by transfection of CD3ζ or replenishment of the amino acid arginine required for its expression. We provide evidence for depletion of arginine in the inflamed hepatic microenvironment as a potential mechanism for these defects in global CD8 T cell signaling and function. These data imply that polarized CD8 T cells within the HBV-infected liver may impede proliferative antiviral effector function, while contributing to the proinflammatory cytokine environment

Early Planet Formation in Embedded Disks (eDisk) III: A first high-resolution view of sub-mm continuum and molecular line emission toward the Class 0 protostar L1527 IRS

Studying the physical and chemical conditions of young embedded disks is crucial to constrain the initial conditions for planet formation. Here, we present Atacama Large Millimeter/submillimeter Array (ALMA) observations of dust continuum at $\sim$0.06" (8 au) resolution and molecular line emission at $\sim$0.17" (24 au) resolution toward the Class 0 protostar L1527 IRS from the Large Program eDisk (Early Planet Formation in Embedded Disks). The continuum emission is smooth without substructures, but asymmetric along both the major and minor axes of the disk as previously observed. The detected lines of $^{12}$CO, $^{13}$CO, C$^{18}$O, H$_2$CO, c-C$_3$H$_2$, SO, SiO, and DCN trace different components of the protostellar system, with a disk wind potentially visible in $^{12}$CO. The $^{13}$CO brightness temperature and the H$_2$CO line ratio confirm that the disk is too warm for CO freeze out, with the snowline located at $\sim$350 au in the envelope. Both molecules show potential evidence of a temperature increase around the disk-envelope interface. SO seems to originate predominantly in UV-irradiated regions such as the disk surface and the outflow cavity walls rather than at the disk-envelope interface as previously suggested. Finally, the continuum asymmetry along the minor axis is consistent with the inclination derived from the large-scale (100" or 14,000 au) outflow, but opposite to that based on the molecular jet and envelope emission, suggesting a misalignment in the system. Overall, these results highlight the importance of observing multiple molecular species in multiple transitions to characterize the physical and chemical environment of young disks.Comment: 27 pages, 16 figures, 2 tables, 10 pages appendix with 12 figures. Accepted for publication in ApJ as one of the first-look papers of the eDisk ALMA Large Progra

Early Planet Formation in Embedded Disks (eDisk). VII. Keplerian Disk, Disk Substructure, and Accretion Streamers in the Class 0 Protostar IRAS 16544-1604 in CB 68

We present observations of the Class 0 protostar IRAS 16544-1604 in CB 68 from the ''Early Planet Formation in Embedded Disks (eDisk)'' ALMA Large program. The ALMA observations target continuum and lines at 1.3-mm with an angular resolution of $\sim$5 au. The continuum image reveals a dusty protostellar disk with a radius of $\sim$30 au seen close to edge-on, and asymmetric structures both along the major and minor axes. While the asymmetry along the minor axis can be interpreted as the effect of the dust flaring, the asymmetry along the major axis comes from a real non-axisymmetric structure. The C$^{18}$O image cubes clearly show the gas in the disk that follows a Keplerian rotation pattern around a $\sim$0.14 $M_{\odot}$ central protostar. Furthermore, there are $\sim$1500 au-scale streamer-like features of gas connecting from North-East, North-North-West, and North-West to the disk, as well as the bending outflow as seen in the $^{12}$CO (2-1) emission. At the apparent landing point of NE streamer, there are SO (6$_5$-5$_4$) and SiO (5-4) emission detected. The spatial and velocity structure of NE streamer can be interpreted as a free-falling gas with a conserved specific angular momentum, and the detection of the SO and SiO emission at the tip of the streamer implies presence of accretion shocks. Our eDisk observations have unveiled that the Class 0 protostar in CB 68 has a Keplerian rotating disk with flaring and non-axisymmetric structure associated with accretion streamers and outflows.Comment: 30 pages, 24 figures, accepted for publication in The Astrophysical Journal as one of the first-look papers of the eDisk ALMA Large Progra

Search for charged Higgs decays of the top quark using hadronic tau decays

We present the result of a search for charged Higgs decays of the top quark, produced in $p\bar{p}$ collisions at $\surd s =$ 1.8 TeV. When the charged Higgs is heavy and decays to a tau lepton, which subsequently decays hadronically, the resulting events have a unique signature: large missing transverse energy and the low-charged-multiplicity tau. Data collected in the period 1992-1993 at the Collider Detector at Fermilab, corresponding to 18.7$\pm$0.7~pb$^{-1}$, exclude new regions of combined top quark and charged Higgs mass, in extensions to the standard model with two Higgs doublets.Comment: uuencoded, gzipped tar file of LaTeX and 6 Postscript figures; 11 pp; submitted to Phys. Rev.

Inclusive jet cross section in pˉp{\bar p p} collisions at s=1.8\sqrt{s}=1.8 TeV

The inclusive jet differential cross section has been measured for jet transverse energies, $E_T$, from 15 to 440 GeV, in the pseudorapidity region 0.1$\leq | \eta| \leq$0.7. The results are based on 19.5 pb$^{-1}$ of data collected by the CDF collaboration at the Fermilab Tevatron collider. The data are compared with QCD predictions for various sets of parton distribution functions. The cross section for jets with $E_T>200$ GeV is significantly higher than current predictions based on O($\alpha_s^3$) perturbative QCD calculations. Various possible explanations for the high-$E_T$ excess are discussed.Comment: 8 pages with 2 eps uu-encoded figures Submitted to Physical Review Letter

Measurement of Dijet Angular Distributions at CDF

We have used 106 pb^-1 of data collected in proton-antiproton collisions at sqrt(s)=1.8 TeV by the Collider Detector at Fermilab to measure jet angular distributions in events with two jets in the final state. The angular distributions agree with next to leading order (NLO) predictions of Quantum Chromodynamics (QCD) in all dijet invariant mass regions. The data exclude at 95% confidence level (CL) a model of quark substructure in which only up and down quarks are composite and the contact interaction scale is Lambda_ud(+) < 1.6 TeV or Lambda_ud(-) < 1.4 TeV. For a model in which all quarks are composite the excluded regions are Lambda(+) < 1.8 TeV and Lambda(-) < 1. 6 TeV.Comment: 16 pages, 2 figures, 2 tables, LaTex, using epsf.sty. Submitted to Physical Review Letters on September 17, 1996. Postscript file of full paper available at http://www-cdf.fnal.gov/physics/pub96/cdf3773_dijet_angle_prl.p

Search for New Particles Decaying to Dijets at CDF

We have used 106 pb^-1 of data collected with the Collider Detector at Fermilab to search for new particles decaying to dijets. We exclude at the 95% confidence level models containing the following new particles: axigluons and flavor universal colorons with mass between 200 and 980 GeV/c, excited quarks with mass between 80 and 570 GeV/c^2 and between 580 and 760 GeV/c^2, color octet technirhos with mass between 260 and 480 GeV/c^2, W' bosons with mass between 300 and 420 GeV/c^2, and E_6 diquarks with mass between 290 and 420 GeV/c^2.Comment: 18 pages, 4 figures, 1 table. Submitted to Physical Review D Rapid Communications. Postscript file of paper is also available at http://www-cdf.fnal.gov/physics/pub97/cdf3276_dijet_search_prd_rc.p