Generalized 3G theorem and application to relativistic stable process on non-smooth open sets

Let G(x,y) and G_D(x,y) be the Green functions of rotationally invariant symmetric \alpha-stable process in R^d and in an open set D respectively, where 0<\alpha < 2. The inequality G_D(x,y)G_D(y,z)/G_D(x,z) \le c(G(x,y)+G(y,z)) is a very useful tool in studying (local) Schrodinger operators. When the above inequality is true with a constant c=c(D)>0, then we say that the 3G theorem holds in D. In this paper, we establish a generalized version of 3G theorem when D is a bounded \kappa-fat open set, which includes a bounded John domain. The 3G we consider is of the form G_D(x,y)G_D(z,w)/G_D(x,w), where y may be different from z. When y=z, we recover the usual 3G. The 3G form G_D(x,y)G_D(z,w)/G_D(x,w) appears in non-local Schrodinger operator theory. Using our generalized 3G theorem, we give a concrete class of functions belonging to the non-local Kato class, introduced by Chen and Song, on \kappa-fat open sets. As an application, we discuss relativistic \alpha-stable processes (relativistic Hamiltonian when \alpha=1) in \kappa-fat open sets. We identify the Martin boundary and the minimal Martin boundary with the Euclidean boundary for relativistic \alpha-stable processes in \kappa-fat open sets. Furthermore, we show that relative Fatou type theorem is true for relativistic stable processes in \kappa-fat open sets. The main results of this paper hold for a large class of symmetric Markov processes, as are illustrated in the last section of this paper. We also discuss the generalized 3G theorem for a large class of symmetric stable Levy processes.Comment: 32 page

The Korean system of innovation and the semiconductor industry

노트 : This paper is written as part of the Science Policy Research Unit/Sussex European Institute-joint project ‘‘Innovation Dynamics of Pacific Asia: Implications for Europe’’

The Relationship Between Leisure Traveler\u27s hotel Attribute Satisfaction and Overall Satisfaction

Manystudies have been conducted about hotel attributesrelated tothehotel choice decision as a part ofacustomer’s pre- purchase behavior(Dolnicar&Otter, 2003). Althoughit iscritical for hotel managerstounderstand post-trip behavior because such behaviorsmaydirectlyinfluence their futurebehavior, therearefew researchstudieswhich examine hotel attributesrelated to acustomer’spost-trip behavior.This studyteststhe relationship between leisure traveler’shotel attribute satisfaction and overall satisfaction in the post-trip behaviorperspectiveina hotel setting andexaminestherelative impactofhotel attributesatisfaction in influencing overall satisfaction. Multiple regressionwas used totestthe relationship and hotel attribute satisfaction isan important antecedent tooverall satisfaction. Theoretical and practical implications ofthe studyare discussed

Teacher Beliefs and Practices Survey: operationalizing the 1997 NAEYC guidelines

This study examined the psychometric properties of a revised measurement, the Teacher Beliefs and Practices Survey, devised for teachers of 3- to 5-year-old children. The measure was designed to reflect the concepts of DAP (developmentally appropriate practices) as presented in the revised 1997 NAEYC guidelines and consisted of 2 scales. Three hundred seventy five surveys completed by public kindergarten teachers in Southeast Louisiana were utilized in the study. Reliability was examined using internal consistency method. Cronbach¡¯s ¥á was .858 for the Beliefs Scale and .787 for the Instructional Activities Scale. Validity of the measure was examined in its content, criterion, and construct (Carmines & Zeller, 1979). Content validity was enhanced by reflecting the feedback from the nationwide experts in early childhood education on the survey before administering the measure to the targeted teachers. Criterion-related validity was supported when the findings showed that one of the sub-measures, the measure of the developmentally inappropriate practices, showed a high correlation with the score from the observed classroom practices. The following results support construct validity: first, the factors uncovered in the survey matched the important concepts of DAP in the guidelines; second, predictors of DAP found to be significant from previous studies were also significant in both of the subscales; third, the low but significant correlation between the Teacher Beliefs and Practices Survey score and a theoretically related measure, the Teacher Educational Attitude Scale (Rescorla et al., 1990) was found. Considering the psychometric properties, the Teacher Beliefs and Practices Survey appears to be a promising measure for critically examining teachers¡¯ beliefs about and practices of DAP

A Study of Russia's First 19th Century Textbook of Korean Texts in Linguistic and Cultural Perspective

Traditionally instruction of speech, grammar and reading in Korean has been carried out in separate educational units. Recently learning the Korean language has shifted from merely mastering grammar to focusing on spoken language and the communication skills. This article sheds the light on the need for integrated language learning activities in the Korean language and culture instruction using the 19th textbook Chunhyangjeon by Kim Byeong-ok. This research examines the Korean Texts of Chunhyangjeon – the first textbook introduced in Russia for reading in the medieval Korean language. The main purpose of this study is to better understand how the reading, grammar, and culture aspects of the Korean language were taught in Russia in the 19th century. The analysis revealed the need for integrating the medieval Korean texts into the Korean reading classes. The importance of combining the integrated Korean language instruction with the direct teaching method is also discussed. The author argues for the need to use both the traditional reading learning method and the mixed approach, which includes reading and understanding the writer, the reader, and the cultural context. Finally, this article is trying to provide a rationale for integrating reading and grammar education for higher learning outcomes in developing linguistic abilities and language comprehension

Carried Interest and Beyond: The Nature of Private Equity Investment and Its International Tax Implications

Private equity funds (PEFs) eliminate entity-level taxation by using pass-through entities. They further minimize their investors’ tax liability by taking the position that profits distributed to both general partners (GPs) and limited partners (LPs) are passive portfolio investment income and taxed preferentially. The taxation of carried interest at low capital gains rates is likely the most infamous loophole. This article challenges such tax position and instead argues that the nature of PEF investment is active. PEFs seek to influence their portfolio companies to increase their value so that they actively manage the companies by acquiring at least 10% of their stock, which does not conceptually accord with portfolio investments. The proposed theory that PEFs are active is further supported by recent proposals on carried interest as well as cases and rulings holding that PEFs are involved in a “trade or business.” This article also considers international tax implications of the new theory: it switches the primary tax jurisdiction to levy tax on PEFs’ crossborder income. This change may be justified for GPs who erode the tax base of a source country, but less justified for LPs because of their genuinely passive involvement, notwithstanding that LPs’ tax-exempt or nonresident status enables GPs’ abusive activities. Finally, determining the true nature of PEF investment and reforming PEF tax accordingly would increase worldwide revenue without significantly reducing the revenue of traditional residence countries, because the traditional residence countries, such as the United States, are also major source countries in the PEF industry

Engineering Pass-Throughs in International Tax: The Case of Private Equity Funds

Fund investment, or indirect investment, does not entail entity-level taxation domestically, so investors enjoy “tax neutrality” between direct and indirect investments made within a country. In contrast, when investments are made across borders, tax neutrality cannot be guaranteed because current international tax regimes are built upon bilateral tax treaties and lack pass-through tax rules for multinational fund investment schemes. This may put investors in a worse tax position than had they invested directly.In response, investors have created many strategies to reduce tax liabilities internationally when investing indirectly. Sometimes those strategies enable investors to pay even less taxes than they would with a tax-neutral benchmark. Recognizing that systematic pass-through taxation more likely would achieve tax neutrality goals, the OECD, through its limited rule-making power, developed several proposals for pass-through treatment. Unfortunately, none of them have been effective, either because of too narrow implementation or because they supply bilateral solutions to a multilateral problem.As an alternative, this Article proposes an innovative multilateral approach in which both the source country and the residence country may look-through certain fund vehicles in intermediary countries and will collect tax as if the investment was made directly from the residence country to the source country. This Article further develops the proposal by demonstrating its feasibility for private equity funds (PEFs). PEFs offer unique opportunities to reform international pass-through taxation because they tend to have only a handful of high-profile investors who rarely change during the fund’s lifetime. Although information about PEF investors notoriously has been less available to tax authorities, new public and private databases as well as a newly enhanced system for the exchange of tax information make such information now more accessible to governments. Tax authorities will be able to obtain information on the considerably small and manageable number of investors behind PEFs and implement pass-through taxation to realize robust tax neutrality goals

Digital Services Tax: A Cross-Border Variation of the Consumption Tax Debate

The rise of highly digitalized businesses, such as Google and Amazon, has strained the traditional income tax rules on nexus and profit allocation. Traditionally, profit is allocated to market countries where consumers are located only if the business has a physical presence. However, in the digital economy, profits can be easily generated in market countries without a physical presence, resulting in tax revenue loss for market countries. In response, market countries have started imposing a new tax, called the digital services tax (DST), on certain digital business models, which has ignited heated debate across the globe. Supporters defend the DST, designed as a turnover style consumption tax, as an effective measure to make up the foregone revenue in the digital economy because it is not bound by the traditional rules of income taxation. Opponents criticize DSTs as “ring-fencing” or segregating certain digital business models, discriminating against American tech giants, and arguably imposing a disguised income tax. The debate has been focused on the imminent impact, such as who is the immediate winner and loser, but the discussion lacks efforts to understand the fundamentals of DSTs, especially with regard to the consumption tax aspect.This Article is the first academic paper that highlights DSTs as a consumption tax and provides normative implications for policy makers deliberating a DST. It argues that a DST, with certain modifications, can be a good solution for the tax challenges of the digital economy. First, the Article offers an in-depth analysis of DSTs’ economic impact in multisided digital platforms. Second, it offers the advantages of DSTs over other types of consumption tax, such as value added tax and cash-flow tax. Finally, it illustrates how the recent Supreme Court case of South Dakota v. Wayfair, Inc., which discusses a sales tax imposed on certain remote sellers, and the subsequent Netflix Tax may shed light on ways to overcome the ring-fencing problem of the DST

Taxing Teleworkers

Since COVID-19 has forced many governments to restrict travel and impose quarantine requirements, telework has become a way of life. The shift towards teleworking is raising tax concerns for workers who work for employers located in another state than where they live. Most source states where these employers are located could not have taxed income of out-of-state teleworkers under the pre-pandemic tax rules. However, several source states have unilaterally extended their sourcing rule on these teleworkers, resulting in unwarranted risk of double taxation — once by the residence state and again by the source state. At this time, there is no uniform guideline by state or federal governments. Recently, New Hampshire, supported by fourteen other states, asked the U.S. Supreme Court to exercise its original jurisdiction challenging Massachusetts’ telecommuting taxes of nonresident teleworkers. Tax commentators believed this case would be one of the most significant tax decisions in recent years, but the Supreme Court declined to hear it. New Jersey also opposes New York’s long-standing telecommuting taxes under the “convenience of the employer” rule. This Article examines the constitutional challenges of maintaining pre-pandemic work arrangements for tax purposes, arguing that a source state’s extraterritorial assertion to tax nonresident teleworkers’ income likely violates the Dormant Commerce and Due Process Clauses. Also, this Article finds the Supreme Court’s decision not to exercise original jurisdiction dissatisfying in light of the substantial increase in remote work. The problem of taxing teleworkers is not temporary because the pandemic drastically reshaped where and how people work. Recognizing the need for a uniform long-term solution, this Article argues Congress should enact federal law to preempt conflicting state law positions and enforce the primacy of residence-based taxation on teleworkers’ income. This proposal would reduce the impact various source states’ tax laws have on interstate commerce, preserve due process, and bolster policy rationales, such as taxpayers’ choice in where they reside and pay taxes as their social obligation to the community