New Tax Issues Arising From the Dodd-Frank Act and Related Changes to Market Practice for Derivatives

The Dodd-Frank Wall Street Reform and Consumer Protection Act ("Dodd-Frank") requires that most over-the-counter ("OTC") derivatives be cleared through a clearinghouse and traded on a regulated exchange. This article discusses a number of U.S. federal income tax issues raised by Dodd-Frank and related changes to market practice for derivatives. The article also provides background discussion on current market practice and the clearing process. The first question addressed by the article is the extent to which formerly-OTC derivatives traded on an exchange will become subject to the special mark-to-market rules of § 1256 that apply to other exchange-traded derivatives. Dodd-Frank partially addresses this issue through an amendment to § 1256 excluding certain types of OTC swaps from its scope. The article discusses a range of possible interpretations of this amendment and suggests some further amendments to the law that could alleviate pressure on the guidance process. The second set of tax issues addressed by this article are those stemming from the fact that the move towards regulated clearing and trading has the effect of increasing substantially the number of swaps that are entered into, or deemed entered into, with upfront payments, which may be treated under long-standing rules as giving rise to a deemed loan between the parties. The article explains the ambiguities of these rules, particularly with respect to centrally cleared swaps and in the case of credit default swaps, and suggests a number of changes to the law

Lie Superalgebra Stability and Branes

The algebra of the generators of translations in superspace is unstable, in the sense that infinitesimal perturbations of its structure constants lead to non-isomorphic algebras. We show how superspace extensions remedy this situation (after arguing that remedy is indeed needed) and review the benefits reaped in the description of branes of all kinds in the presence of the extra dimensions.Comment: Talk given at the conference ``Brane New World and Non-commutative Geometry'', held in Torino, October 2000. To appear in the proceedings by World Scientific. 10 pages, 1 figur

Commuting symmetry operators of the Dirac equation, Killing-Yano and Schouten-Nijenhuis brackets

In this paper we derive the most general first-order symmetry operator commuting with the Dirac operator in all dimensions and signatures. Such an operator splits into Clifford even and Clifford odd parts which are given in terms of odd Killing-Yano and even closed conformal Killing-Yano inhomogeneous forms respectively. We study commutators of these symmetry operators and give necessary and sufficient conditions under which they remain of the first-order. In this specific setting we can introduce a Killing-Yano bracket, a bilinear operation acting on odd Killing-Yano and even closed conformal Killing-Yano forms, and demonstrate that it is closely related to the Schouten-Nijenhuis bracket. An important non-trivial example of vanishing Killing-Yano brackets is given by Dirac symmetry operators generated from the principal conformal Killing-Yano tensor [hep-th/0612029]. We show that among these operators one can find a complete subset of mutually commuting operators. These operators underlie separability of the Dirac equation in Kerr-NUT-(A)dS spacetimes in all dimensions [arXiv:0711.0078].Comment: 37 pages, no figure

Double bracket dissipation in kinetic theory for particles with anisotropic interactions

We derive equations of motion for the dynamics of anisotropic particles directly from the dissipative Vlasov kinetic equations, with the dissipation given by the double bracket approach (Double Bracket Vlasov, or DBV). The moments of the DBV equation lead to a nonlocal form of Darcy's law for the mass density. Next, kinetic equations for particles with anisotropic interaction are considered and also cast into the DBV form. The moment dynamics for these double bracket kinetic equations is expressed as Lie-Darcy continuum equations for densities of mass and orientation. We also show how to obtain a Smoluchowski model from a cold plasma-like moment closure of DBV. Thus, the double bracket kinetic framework serves as a unifying method for deriving different types of dynamics, from density--orientation to Smoluchowski equations. Extensions for more general physical systems are also discussed.Comment: 19 pages; no figures. Submitted to Proc. Roy. Soc.

Efficient indexing of necklaces and irreducible polynomials over finite fields

We study the problem of indexing irreducible polynomials over finite fields, and give the first efficient algorithm for this problem. Specifically, we show the existence of poly(n, log q)-size circuits that compute a bijection between {1, ... , |S|} and the set S of all irreducible, monic, univariate polynomials of degree n over a finite field F_q. This has applications in pseudorandomness, and answers an open question of Alon, Goldreich, H{\aa}stad and Peralta[AGHP]. Our approach uses a connection between irreducible polynomials and necklaces ( equivalence classes of strings under cyclic rotation). Along the way, we give the first efficient algorithm for indexing necklaces of a given length over a given alphabet, which may be of independent interest

Entry into puberty is reflected in changes in hormone production but not in testicular receptor expression in Atlantic salmon (Salmo salar)

Background Puberty in male Atlantic salmon in aquaculture can start as early as after the first winter in seawater, stunts growth and entails welfare problems due to the maturation-associated loss of osmoregulation capacity in seawater. A better understanding of the regulation of puberty is the basis for developing improved cultivation approaches that avoid these problems. Our aim here was to identify morphological and molecular markers signaling the initiation of, and potential involvement in, testis maturation. Methods In the first experiment, we monitored for the first time in large Atlantic salmon males several reproductive parameters during 17 months including the first reproductive cycle. Since testicular growth accelerated after the Winter solstice, we focused in the second experiment on the 5 months following the winter solstice, exposing fish from February 1 onwards to the natural photoperiod (NL) or to continuous additional light (LL). Results In the first experiment, testis weight, plasma androgens and pituitary gonadotropin transcript levels increased with the appearance of type B spermatogonia in the testis, but testicular transcript levels for gonadotropin or androgen receptors did not change while being clearly detectable. In the second experiment, all males kept under NL had been recruited into puberty until June. However, recruitment into puberty was blocked in ~ 40% of the males exposed to LL. The first morphological sign of recruitment was an increased proliferation activity of single spermatogonia and Sertoli cells. Irrespective of the photoperiod, this early sign of testis maturation was accompanied by elevated pituitary gnrhr4 and fshb and testicular igf3 transcript levels as well as increased plasma androgen levels. The transition into puberty occurred again with stable testicular gonadotropin and androgen receptor transcript levels.publishedVersio

Extensions, expansions, Lie algebra cohomology and enlarged superspaces

After briefly reviewing the methods that allow us to derive consistently new Lie (super)algebras from given ones, we consider enlarged superspaces and superalgebras, their relevance and some possible applications.Comment: 9 pages. Invited talk delivered at the EU RTN Workshop, Copenhagen, Sep. 15-19 and at the Argonne Workshop on Branes and Generalized Dynamics, Oct. 20-24, 2003. Only change: wrong number of a reference correcte

Inter-muscular coherence in speed skaters with skater's cramp

Introduction: Skater's cramp is a career-ending movement disorder in expert speed skaters noted to be a likely task-specific dystonia. In other movement disorders, including task-specific dystonia, studies have found evidence of central dysregulation expressed as higher inter-muscular coherence. We looked at whether inter-muscular coherence was higher in affected skaters as a possible indicator that it is centrally driven, and by extension further evidence it is a task-specific dystonia.Methods: In 14 affected and 14 control skaters we calculated inter-muscular coherence in the theta-band in a stationary task where tonic muscle activation was measured at 10%, 20% and 50% of maximum voluntary contraction. Additionally, we calculated wavelet coherence while skating at key moments in the stroke cycle.Results: Coherence did not differ in the stationary activation task. While skating, coherence was higher in the impacted leg of affected skaters compared to their non-impacted leg, p = .05, η2 = 0.031, and amplitude of electromyography correlated with coherence in the impacted leg, p = .009, R2adjusted = 0.41. A sub-group of severely affected skaters (n = 6) had higher coherence in the impacted leg compared to the left and right leg of controls, p = .02, Cohen's d = 1.59 and p = .01, Cohen's d = 1.63 respectively. Results were less clear across the entire affected cohort probably due to a diverse case-mix.Conclusion: Our results of higher coherence in certain severe cases of skater's cramp is preliminary evidence of a central dysregulation, making the likelihood it is a task-specific dystonia higher.</p

Bose-Einstein Correlations of Pion Wavepackets

A wavepacket model for a system of free pions, which takes into account the full permutation symmetry of the wavefunction and which is suitable for any phase space parametrization is developed. The properties of the resulting mixed ensembles and the two-particle correlation function are discussed. A physical interpretation of the chaoticity lambda as localizat of the pions in the source is presented. Two techniques to generate test-particles, which satisfy the probability densities of the wavepacket state, are studied: 1. A Monte Carlo procedure in momentum space based on the standard Metropolis technique. 2. A molecular dynamic procedure using Bohm's quantum theory of motion. In order to reduce the numerical complexity, the separation of the wavefunction into momentum space clusters is discussed. In this context th influence of an unauthorized factorization of the state, i. e. the omissio of interference terms, is investigated. It is shown that the correlation radius remains almost uneffected, but the chaoticity parameter decreases substantially. A similar effect is observed in systems with high multiplic where the omission of higher order corrections in the analysis of two-part correlations causes a reduction of the chaoticity and the radius. The approximative treatment of the Coulomb interaction between pions and source is investigated. The results suggest that Coulomb effects on the co radii are not symmetric for pion pairs of different charges. For negative the radius, integrated over the whole momentum spectrum, increases substan while for positive pions the radius remains almost unchanged.Comment: 15 pages, 8 figures, 0.8 Mb, uses ljour2-macro, Submitted to Z. Phys. A (1997