THE INCOME TAX LIABILITY OF DIVIDENDS IN LIQUIDATION

The development of a scheme at once equitable and constitutional for the taxation of corporate distributions has been one of the more difficult problems confronting Congress and the courts since the adoption of the income tax amendment. Doubtless the chief reason for this difficulty has been the fact that the income tax liability of a shareholder upon such a distribution has not been determinable merely by ascertaining whether the amounts received are the variety of receipts commonly regarded by their recipients as income,- in a word, by determining whether they constitute a gain to the shareholder. Rather, it is a commonplace that Congress has seen fit to provide in the recent revenue acts that the rate and the method of taxing the distribution to the shareholder shall vary with the source of the distribution. Thus, although a dividend from corporate surplus accumulated since February 28, 1913, is subject to the surtax, a dividend from corporate surplus accumulated before March 1, 1913 (which in many cases could constitutionally be taxed) may not be taxable at all, although in the Revenue Act of 1924, it has been given an important effect in determining the tax liability of future distributions. Again, a distribution neither out of increase in value of property accrued before March 1, 1913, nor out of corporate earnings or profits, if it is subject to tax at all, may not be taxable at more than the 12,1/2 per cent rate upon capital gains. The weighing of the two considerations affecting income tax liability -the source of the distribution on the one hand, and the gain to the shareholder on the other-becomes most troublesome in connection with distributions in liquidations, since in such cases it is common for all the possible sources and consequently all the various exemptions and methods of taxation to be involved. Since the Treasury and attorneys for taxpayers are not agreed upon the proper interpretation of the provisions of the more recent revenue acts in this respect, and since few of the situations have been judicially considered, a discussion of some of the outstanding problems may be in order

Self-stabilised fractality of sea-coasts through damped erosion

Erosion of rocky coasts spontaneously creates irregular seashores. But the geometrical irregularity, in turn, damps the sea-waves, decreasing the average wave amplitude. There may then exist a mutual self-stabilisation of the waves amplitude together with the irregular morphology of the coast. A simple model of such stabilisation is studied. It leads, through a complex dynamics of the earth-sea interface, to the appearance of a stationary fractal seacoast with dimension close to 4/3. Fractal geometry plays here the role of a morphological attractor directly related to percolation geometry.Comment: 4 pages, 5 figure

40Ar/39Ar ages of the sill complex of the Karoo large igneous province: implications for the Pliensbachian-Toarcian climate change.

Reliable geochronological results gathered so far (n = 76) have considerably constrained the timing of the emplacement of the Karoo large igneous province (LIP). Yet strikingly missing from this dating effortis the huge southern sill complex cropping out in the >0.6 x 10(6) km2 Main Karoo sedimentary basin. We present 16 new 40Ar/39Ar analyses carried out on fresh plagioclase and biotite separates from 15 sill samples collected along a N-S trend in the eastern part of the basin. The results show a large range of plateau and miniplateau ages (176.2 +- 1.3 to 183.8 +- 2.4 Ma), with most dates suggesting a -3 Ma (181-184 Ma) duration for the main sill events. The available age database allows correlation of the Karoo LIP emplacement with the Pliensbachian-Toarcian second-order biotic extinction, the global warming, and the Toarcian anoxic event (provided that adequate calibration between the 40K and 238U decay constant ismade). The mass extinction and the isotopic excursions recorded at the base of the Toarcian appear to be synchronous with both the increase of magma emission of the Karoo LIP and the emplacement of the sills.The CO2 and SO2 derived from both volcanic emissions as well as carbon-rich sedimentary layers intrudedby sills might be the main culprits of the Pliensbachian-Toarcian climate perturbations. We propose that the relatively low eruption rate of the Karoo LIP is one of the main reasons explaining why its impact on thebiosphere is relatively low contrary to, e.g., the CAMP (Triassic-Jurassic) and Siberia (Permo-Triassic) LIPs

The hard work of reparative futures: Exploring the potential of creative and convivial encounters in post-conflict Uganda

This is the author accepted manuscript.In this paper we empirically explore the ways in which young people were enroled in a multimodal exhibition to creatively produce narratives of their past, presents and futures. We look at the different ways this work was framed, and how all memory work and, we argue, future work is relational, interactionally produced and situated in dynamic and unfolding social and political frameworks. We look at the ways young people described the work of producing accounts of their futures within that setting, and the different forms of labour involved in that process. We explore the encounters that fostered local, more humble, acts of care and repair, and how those everyday practices might help build towards reparative futures.British Academ