Twilight of the International Consensus: How Multinationals Squandered Their Tax Privileges

In September 2013, Exxon Mobil Corp. announced it would recognize gay marriage for its employees. This was front-page news, right up there with a New Jersey Supreme Court judge telling the state it had to do the same. Why? Because Exxon is a politically conservative oil company that makes most of its political donations to Republicans? No, because Exxon is such a huge non-state actor that anything it does is tantamount to a government action. In The Power Elite, C. Wright Mills cogently explained how giant multinational corporations had escaped the writ of national governments. Exxon is one of the world’s ten largest multinational corporate groups measured by market value. At the time of this writing, nine companies on that list were American, along with around half of the fifty. Some of the world’s largest companies pay very little tax anywhere in the world. But to their home governments, they are often national champions. Some other countries’ multinationals are unfairly skipping-out on their corporate tax obligations to Organization for Economic Cooperation and Development (OECD) member and observer countries. That was the genesis of the OECD Base Erosion and Profit Shifting project (BEPS), which has produced an action plan designed to repair and preserve the fragile international consensus in the short run, but may end up upsetting it in the long run. In the long run, the international consensus is dead, and everyone knows it; but BEPS has to be tried and allowed to fail first. This Essay addresses issues with taxing multinationals and how they abuse their tax privileges. Further, this Essay discusses how BEPS must run its course and how a new international consensus is necessary to combat the shortfalls of BEPS

Petition for a Writ of Habeas Corpus

Sheppard exhausted his available state remedies as required by Title 28, USC, Section 2254. On May 31, 1956, the Supreme Court of Ohio affirmed his conviction, 165 0.S. 293; a petition for rehearing was denied on July 5, 1956. The Supreme Court of the United States denied certiorari, 352 U.S. 910; a petition for rehearing was denied, 352 U.S. 955 . A petition for a writ of habeas corpus was dismissed by the Supreme Court of Ohio, 170 0.S. 551 (1958). Sheppard asserted there were no further avenues of revue open to him in the courts of Ohio, and any proceeding therein would be unavailing, for the Ohio courts generally are so biased and prejudiced against him that he will be denied relief in any event. The petition states that Ohio violated Sheppard\u27s federal constitutional right to a fair and impartial trial, and more specifically his federal constitutional right to counsel. Sheppard\u27s repeated motions for change of venue to a district or locale not saturated by the massive prejudicial and inflammatory publicity stimulated were likewise denied. Claims of the petition focused on the personal influences of the local court judge, reelection publicity, and the local media\u27s inflammatory published opinions amongst numerous incidents of abuse of power by government officials. As a result of the facts and circumstances set forth, petitioner was denied a fair and impartial trial, and was further denied the equal protection of the laws of the state of Ohio; petitioner\u27s trial was not a trial at all, but a sham proceeding conducted and controlled by persons of official responsibility whose primary purpose was to satisfy the populace which had been convinced by irresponsible news media that petitioner was guilty despite the marked lack of evidence tending to prove such guilt; petitioner was subjected to trial by newspaper, and was subjected specifically to the perverted power of the Cleveland Press, which sought to and did cause petitioner to be convicted in violation of his constitutional rights

Affidavit of Poverty and Motion to Proceed in Forma Pauperis in Habeas Corpus Proceedings

While incarcerated in the Ohio State Penitentiary serving a sentence of life imprisonment, Sam Sheppard submitted this affidavit and motion claiming his liberty was restrained in violation of the United States Constitution. Sheppard, insolvent, made this affidavit for the purpose of availing himself of the rights and privileges afforded indigents under Title 28 U.S. C., § 1915

Petition for a Writ of Habeas Corpus

Sheppard exhausted his available state remedies as required by Title 28, USC, Section 2254. On May 31, 1956, the Supreme Court of Ohio affirmed his conviction, 165 0.S. 293; a petition for rehearing was denied on July 5, 1956. The Supreme Court of the United States denied certiorari, 352 U.S. 910; a petition for rehearing was denied, 352 U.S. 955 . A petition for a writ of habeas corpus was dismissed by the Supreme Court of Ohio, 170 0.S. 551 (1958). Sheppard asserted there were no further avenues of revue open to him in the courts of Ohio, and any proceeding therein would be unavailing, for the Ohio courts generally are so biased and prejudiced against him that he will be denied relief in any event. The petition states that Ohio violated Sheppard\u27s federal constitutional right to a fair and impartial trial, and more specifically his federal constitutional right to counsel. Sheppard\u27s repeated motions for change of venue to a district or locale not saturated by the massive prejudicial and inflammatory publicity stimulated were likewise denied. Claims of the petition focused on the personal influences of the local court judge, reelection publicity, and the local media\u27s inflammatory published opinions amongst numerous incidents of abuse of power by government officials. As a result of the facts and circumstances set forth, petitioner was denied a fair and impartial trial, and was further denied the equal protection of the laws of the state of Ohio; petitioner\u27s trial was not a trial at all, but a sham proceeding conducted and controlled by persons of official responsibility whose primary purpose was to satisfy the populace which had been convinced by irresponsible news media that petitioner was guilty despite the marked lack of evidence tending to prove such guilt; petitioner was subjected to trial by newspaper, and was subjected specifically to the perverted power of the Cleveland Press, which sought to and did cause petitioner to be convicted in violation of his constitutional rights

Reverse genetics in Candida albicans predicts ARF cycling is essential for drug resistance and virulence

Peer reviewedPublisher PD

The influence of end of day silicone hydrogel daily disposable contact lens fit on ocular comfort, physiology and lens wettability

Purpose: To quantify the end-of-day silicone-hydrogel daily disposable contact lens fit and its influence of on ocular comfort, physiology and lens wettability. Methods: Thirty-nine subjects (22.1. ±. 3.5 years) were randomised to wear each of 3 silicone-hydrogel daily-disposable contact lenses (narafilcon A, delefilcon A and filcon II 3), bilaterally, for one week. Lens fit was assessed objectively using a digital video slit-lamp at 8, 12 and 16. h after lens insertion. Hyperaemia, non-invasive tear break-up time, tear meniscus height and comfort were also evaluated at these timepoints, while corneal and conjunctival staining were assessed on lens removal. Results: Lens fit assessments were not different between brands (P > 0.05), with the exception of the movement at blink where narafilcon A was more mobile. Overall, lag reduced but push-up speed increased from 8 to 12. h (P 0.05). Movement-on-blink was unaffected by wear-time (F = 0.403, P = 0.670). A more mobile lens fit with one brand did not indicate that person would have a more mobile fit with another brand (r = -0.06 to 0.63). Lens fit was not correlated with comfort, ocular physiology or lens wettability (P > 0.01). Conclusions: Among the lenses tested, objective lens fit changed between 8. h and 12. h of lens wear. The weak correlation in individual lens fit between brands indicates that fit is dependent on more than ocular shape. Consequently, substitution of a different lens brand with similar parameters will not necessarily provide comparable lens fit

The effect of lighting conditions and use of headlights on drivers’ perception and appraisal of approaching vehicles at junctions

Use of Daytime Running Lights (DRL) is mandatory in many countries for motorcycles, and in some for cars. However, in developing countries DRLs may be optional or compliance low. The effect of car or motorcycle headlights and lighting conditions on Malaysian drivers’ ability to perceive and judge the safety of pulling out was investigated. Stimuli were photographs depicting either daytime or nighttime taken at a T-junction with approaching vehicles with headlights on or off. Headlights improved drivers’ ability to perceive cars and motorcycles in the nighttime photographs but not the daytime photographs, although this could be due to the bright weather in the photographs. Drivers judged it less safe to pull out when approaching motorcycles had headlights on than off, regardless of the lighting conditions, supporting the utility of DRL for motorcycles. Headlights did not affect judgments for cars, questionning the utility of DRL for cars

ECM microenvironment unlocks brown adipogenic potential of adult human bone marrow-derived MSCs

Key to realizing the diagnostic and therapeutic potential of human brown/brite adipocytes is the identification of a renewable, easily accessible and safe tissue source of progenitor cells, and an efficacious in vitro differentiation protocol. We show that macromolecular crowding (MMC) facilitates brown adipocyte differentiation in adult human bone marrow mesenchymal stem cells (bmMSCs), as evidenced by substantially upregulating uncoupling protein 1 (UCP1) and uncoupled respiration. Moreover, MMC also induced ‘browning’ in bmMSC-derived white adipocytes. Mechanistically, MMC creates a 3D extracellular matrix architecture enshrouding maturing adipocytes in a collagen IV cocoon that is engaged by paxillin-positive focal adhesions also at the apical side of cells, without contact to the stiff support structure. This leads to an enhanced matrix-cell signaling, reflected by increased phosphorylation of ATF2, a key transcription factor in UCP1 regulation. Thus, tuning the dimensionality of the microenvironment in vitro can unlock a strong brown potential dormant in bone marrow

Accurate Galactic 21-cm H I measurements with the NRAO Green Bank Telescope

Aims: We devise a data reduction and calibration system for producing highly-accurate 21-cm H I spectra from the Green Bank Telescope (GBT) of the NRAO. Methods: A theoretical analysis of the all-sky response of the GBT at 21 cm is made, augmented by extensive maps of the far sidelobes. Observations of radio sources and the Moon are made to check the resulting aperture and main beam efficiencies. Results: The all-sky model made for the response of the GBT at 21 cm is used to correct for "stray" 21-cm radiation reaching the receiver through the sidelobes rather than the main beam. This reduces systematic errors in 21-cm measurements by about an order of magnitude, allowing accurate 21-cm H I spectra to be made at about 9' angular resolution with the GBT. At this resolution the procedures discussed here allow for measurement of total integrated Galactic H I line emission, W, with errors of 3 K km s^-1, equivalent to errors in optically thin N_HI of 5 x 10^18 cm^-2.Comment: 49 pages, 25 figures; A&A, in pres

The Kuiper Belt and Other Debris Disks

We discuss the current knowledge of the Solar system, focusing on bodies in the outer regions, on the information they provide concerning Solar system formation, and on the possible relationships that may exist between our system and the debris disks of other stars. Beyond the domains of the Terrestrial and giant planets, the comets in the Kuiper belt and the Oort cloud preserve some of our most pristine materials. The Kuiper belt, in particular, is a collisional dust source and a scientific bridge to the dusty "debris disks" observed around many nearby main-sequence stars. Study of the Solar system provides a level of detail that we cannot discern in the distant disks while observations of the disks may help to set the Solar system in proper context.Comment: 50 pages, 25 Figures. To appear in conference proceedings book "Astrophysics in the Next Decade