Tax Exemptions for Charitable Single-Member Limited Liability Companies

This summer, the IRS issued long-awaited guidance on the deductibility of charitable contributions made to a single-member limited liability company (“SMLLC”) that is wholly-owned by a charitable organization exempt from federal income tax as a organization described in Section 501(c)(3). Previously, in a 2001 private letter ruling, the IRS confirmed that a SMLLC wholly-owned by a U.S. charity did not need to submit a separate application for recognition of federal income tax exemption, but declined to rule on whether contributions made to the SMLLC would be deductible under Section 170 as charitable contributions. An article in the IRS Continuing Professional Education Text for the fiscal year 2001 stated that “[g]uidance on this issue will be forthcoming in the near future.” Notice 2012-52 provides this guidance. In Notice 2012-52, the IRS ruled that a contribution to a domestic SMLLC that is wholly owned by a U.S. charity would be treated as a deductible charitable contribution, assuming all the requirements of Section 170 are met. This article discusses the requirements for federal income tax exemption of a SMLLC and the deductibility of contributions made to the SMLLC as well as the availability of Texas state tax exemptions for the SMLLC

A Data Model to Manage Data for Water Resources Systems Modeling

Current practices to identify, organize, analyze, and serve data to water resources systems models are typically model and dataset-specific. Data are stored in different formats, described with different vocabularies, and require manual, model-specific, and time-intensive manipulations to find, organize, compare, and then serve to models. This paper presents the Water Management Data Model (WaMDaM) implemented in a relational database. WaMDaM uses contextual metadata, controlled vocabularies, and supporting software tools to organize and store water management data from multiple sources and models and allow users to more easily interact with its database. Five use cases use thirteen datasets and models focused in the Bear River Watershed, United States to show how a user can identify, compare, and choose from multiple types of data, networks, and scenario elements then serve data to models. The database design is flexible and scalable to accommodate new datasets, models, and associated components, attributes, scenarios, and metadata

Nonprofit Executive Compensation

Excessive compensation paid to nonprofit executives and board members is one of the key issues concerning charitable organizations that garner the attention of the general public and Congress. Charitable organizations may pay reasonable compensation to their directors, executive officers and employees for their services without violating applicable federal tax law or state law. The determination of reasonable compensation depends on several factors – the budget of the organization being the most significant factor. Other factors include the number of employees of the organization, the particular sector of the charitable community served by the organization, the geographic location of the organization, the focus of the organization as being national or local, the length of the employee’s service and external market forces. Even if executive compensation is considered reasonable in light of the foregoing factors, the perception that a charitable organization is paying excessive compensation can be damaging to the organization’s reputation. Some nonprofit executive salaries have reached seven figures, particularly in the larger health care systems and higher education.2 In some cases, the highest paid employee of a charitable organization is not its chief executive officer, but instead may be a senior administrator or key physician of a large urban medical center, a key athletic coach at a Division I university, or a chief investment officer of a university or foundation with a large endowment. Reports of high nonprofit executive compensation have lead the Internal Revenue Service to conduct an Executive Compensation Compliance Initiative in 2004 (with its findings published in March 2007, discussed below), and the Internal Revenue Service continues to scrutinize nonprofit executive compensation. In addition, because nonprofit executive compensation must be reported annually on the organization’s Form 990, the general public, the media, and charity watchdog organizations also scrutinize nonprofit executive compensation. Therefore, it is important for charitable organizations not only to understand the federal tax law governing the payment of reasonable compensation to their directors, officers and key employees, but also to understand their reporting obligations and best practices with respect to executive compensation to avoid undue scrutiny

Exotic Axions

We show that axion phenomenology may be significantly different than conventionally assumed in theories which exhibit late phase transitions (below the QCD scale). In such theories one can find multiple pseudoscalars with axion-like couplings to matter, including a string scale axion, whose decay constant far exceeds the conventional cosmological bound. Such theories have several dark matter candidates.Comment: 5 pages, 1 figure, References adde

The Expected Lifetime of “Single-Address-Space” Operating Systems

Trends toward shared-memory programming paradigms, large (64-bit) address spaces, and memory-mapped files have led some to propose the use of a single virtual-address space, shared by all processes and processors. Typical proposals require the single address space to contain all process-private data, shared data, and stored files. To simplify management of an address space where stale pointers make it difficult to re-use addresses, some have claimed that a 64-bit address space is sufficiently large that there is no need to ever re-use addresses. Unfortunately, there has been no data to either support or refute these claims, or to aid in the design of appropriate address-space management policies. In this paper, we present the results of extensive kernel-level tracing of the workstations in our department, and discuss the implications for single-address-space operating systems. We found that single-address-space systems will not outgrow the available address space, but only if reasonable space-allocation policies are used, and only if the system can adapt as larger address spaces become available

Implications of Data Sampling Resolution on Water Use Simulation, End-Use Disaggregation, And Demand Management

Understanding the tradeoff between the information of high-resolution water use data and the costs of smart meters to collect data with sub-minute resolution is crucial to inform smart meter networks. To explore this tradeoff, we first present STREaM, a STochastic Residential water End-use Model that generates synthetic water end-use time series with 10-s and progressively coarser sampling resolutions. Second, we apply a comparative framework to STREaM output and assess the impact of data sampling resolution on end-use disaggregation, post meter leak detection, peak demand estimation, data storage, and meter availability. Our findings show that increased sampling resolution allows more accurate end-use disaggregation, prompt water leakage detection, and accurate and timely estimates of peak demand. Simultaneously, data storage requirements and limited product availability mean most large-scale, commercial smart metering deployments sense data with hourly, daily, or coarser sampling frequencies. Overall, this work provides insights for further research and commercial deployment of smart water meters

Characterization of the OCO-2 instrument line shape functions using on-orbit solar measurements

Accurately characterizing the instrument line shape (ILS) of the Orbiting Carbon Observatory-2 (OCO-2) is challenging and highly important due to its high spectral resolution and requirement for retrieval accuracy (0. 25 %) compared to previous spaceborne grating spectrometers. On-orbit ILS functions for all three bands of the OCO-2 instrument have been derived using its frequent solar measurements and high-resolution solar reference spectra. The solar reference spectrum generated from the 2016 version of the Total Carbon Column Observing Network (TCCON) solar line list shows significant improvements in the fitting residual compared to the solar reference spectrum currently used in the version 7 Level 2 algorithm in the O₂ A band. The analytical functions used to represent the ILS of previous grating spectrometers are found to be inadequate for the OCO-2 ILS. Particularly, the hybrid Gaussian and super-Gaussian functions may introduce spurious variations, up to 5 % of the ILS width, depending on the spectral sampling position, when there is a spectral undersampling. Fitting a homogeneous stretch of the preflight ILS together with the relative widening of the wings of the ILS is insensitive to the sampling grid position and accurately captures the variation of ILS in the O₂ A band between decontamination events. These temporal changes of ILS may explain the spurious signals observed in the solar-induced fluorescence retrieval in barren areas

Monthly Paleostreamflow Reconstruction from Annual Tree-Ring Chronologies

Paleoclimate reconstructions are increasingly used to characterize annual climate variability prior to the instrumental record, to improve estimates of climate extremes, and to provide a baseline for climate-change projections. To date, paleoclimate records have seen limited engineering use to estimate hydrologic risks because water systems models and managers usually require streamflow input at the monthly scale. This study explores the hypothesis that monthly streamflows can be adequately modeled by statistically decomposing annual flow reconstructions. To test this hypothesis, a multiple linear regression model for monthly streamflow reconstruction is presented that expands the set of predictors to include annual streamflow reconstructions, reconstructions of global circulation, and potential differences among regional tree-ring chronologies related to tree species and geographic location. This approach is used to reconstruct 600 years of monthly streamflows at two sites on the Bear and Logan rivers in northern Utah. Nash-Sutcliffe Efficiencies remain above zero (0.26–0.60) for all months except April and Pearson’s correlation coefficients (R) are 0.94 and 0.88 for the Bear and Logan rivers, respectively, confirming that the model can adequately reproduce monthly flows during the reference period (10/1942 to 9/2015). Incorporating a flexible transition between the previous and concurrent annual reconstructed flows was the most important factor for model skill. Expanding the model to include global climate indices and regional tree-ring chronologies produced smaller, but still significant improvements in model fit. The model presented here is the only approach currently available to reconstruct monthly streamflows directly from tree-ring chronologies and climate reconstructions, rather than using resampling of the observed record. With reasonable estimates of monthly flow that extend back in time many centuries, water managers can challenge systems models with a larger range of natural variability in drought and pluvial events and better evaluate extreme events with recurrence intervals longer than the observed record. Establishing this natural baseline is critical when estimating future hydrologic risks under conditions of a non-stationary climate

The ACS Survey of Galactic Globular Clusters: M54 and Young Populations in the Sagittarius Dwarf Spheroidal Galaxy

We present new Hubble Space Telescope photometry of the massive globular cluster M54 (NGC 6715) and the superposed core of the tidally disrupted Sagittarius (Sgr) dSph galaxy as part of the ACS Survey of Galactic Globular Clusters. Our deep (F606W~26.5), high-precision photometry yields an unprecedentedly detailed color-magnitude diagram showing the extended blue horizontal branch and multiple main sequences of the M54+Sgr system. The distance and reddening to M54 are revised usingboth isochrone and main-sequence fitting to (m-M)_0=17.27 and E(B-V)=0.15. Preliminary assessment finds the M54+Sgr field to be dominated by the old metal-poor populations of Sgr and the globular cluster. Multiple turnoffs indicate the presence of at least two intermediate-aged star formation epochs with 4 and 6 Gyr ages and [Fe/H]=-0.4 to -0.6. We also clearly show, for the first time, a prominent, 2.3 Gyr old Sgr population of near-solar abundance. A trace population of even younger (0.1-0.8 Gyr old), more metal-rich ([Fe/H]\sim0.6) stars is also indicated. The Sgr age-metallicity relation is consistent with a closed-box model and multiple (4-5) star formation bursts over the entire life of the satellite, including the time since Sgr began disrupting.Comment: Accepted to ApJ Letter; 11 pages, 2 figures; figure 1 uploaded as jpg; paper in ApJ format with full-resolution figures available at: http://www.astro.ufl.edu/~ata/public_hstgc/paperIV/paperIV.p

Elevated empathy in adults following childhood trauma.

Traumatic events increase the risk of depression, but there is also evidence that adversity can lead to posttraumatic growth, including increased compassion and prosocial behavior. To date there is no empirical research pinpointing childhood trauma to an increase in trait empathy in adulthood. Although somewhat counter-intuitive, this might be predicted if trauma not only increases fear of future threat but also renders the individual more sensitive to suffering in others. We explored this possible link using multiple studies, self-report measures, and non-clinical samples. Results across samples and measures showed that, on average, adults who reported experiencing a traumatic event in childhood had elevated empathy levels compared to adults who did not experience a traumatic event. Further, the severity of the trauma correlated positively with various components of empathy. These findings suggest that the experience of a childhood trauma increases a person's ability to take the perspective of another and to understand their mental and emotional states, and that this impact is long-standing. Future research needs to test if this is seen on performance measures, and how these findings extend to clinical populations.Jaso