Cross Border State Sales and Use Taxation After \u3ci\u3eSouth Dakota v. Wayfair\u3c/i\u3e: A New Paradigm for E-Commerce

For over 50 years, U.S. Supreme Court precedents held that state sales taxes could not be constitutionally applied against retailers with no physical presence in the taxing states. As a result, many states implemented use tax laws to supplement sales tax laws, essentially requiring each resident consumer to self-report and pay taxes on purchases made from out of state retailers. However, these use tax laws were largely ignored. Moreover, with the advent of online retail (“e-tail”), many sales on which states previously collected sales tax from local stores essentially converted to “tax-free” sales because many online sellers (“e-tailers”) had no physical nexus to the states in which the products were delivered. As online sales continued to take up a larger percentage of all purchases, states struggled to secure sales and use tax revenue consistent with the physical nexus standard. In recent years, many states implemented laws that required e-tailers to collect sales taxes not based upon physical presence, but upon annual dollar value or number of sales into the states (called, “economic nexus”). However, enforceability of the economic nexus laws was questionable in light of past U.S. Supreme Court decisions. Additionally, with more than 9,600 sales taxing jurisdictions with varying rules and rates, many argued that compliance would create an undue burden on interstate commerce in violation of the Commerce Clause of the U.S. Constitution. South Dakota was one of the states to implement an economic nexus law, and it was challenged on constitutional grounds. In June 2018, in the matter of South Dakota v. Wayfair, et al., the U.S. Supreme Court held in favor of South Dakota, overturning the physical nexus standard and allowing economic nexus sales taxation of online sales based upon dollar value or number of sales alone. This article summarizes state sales and use tax laws, prior Supreme Court precedent, and the South Dakota v. Wayfair decision. It then examines current economic nexus and similar laws, compliance issues, and possible solutions for the e-tailer client

Improved profile fitting and quantification of uncertainty in experimental measurements of impurity transport coefficients using Gaussian process regression

The need to fit smooth temperature and density profiles to discrete observations is ubiquitous in plasma physics, but the prevailing techniques for this have many shortcomings that cast doubt on the statistical validity of the results. This issue is amplified in the context of validation of gyrokinetic transport models (Holland et al 2009 Phys. Plasmas 16 052301), where the strong sensitivity of the code outputs to input gradients means that inadequacies in the profile fitting technique can easily lead to an incorrect assessment of the degree of agreement with experimental measurements. In order to rectify the shortcomings of standard approaches to profile fitting, we have applied Gaussian process regression (GPR), a powerful non-parametric regression technique, to analyse an Alcator C-Mod L-mode discharge used for past gyrokinetic validation work (Howard et al 2012 Nucl. Fusion 52 063002). We show that the GPR techniques can reproduce the previous results while delivering more statistically rigorous fits and uncertainty estimates for both the value and the gradient of plasma profiles with an improved level of automation. We also discuss how the use of GPR can allow for dramatic increases in the rate of convergence of uncertainty propagation for any code that takes experimental profiles as inputs. The new GPR techniques for profile fitting and uncertainty propagation are quite useful and general, and we describe the steps to implementation in detail in this paper. These techniques have the potential to substantially improve the quality of uncertainty estimates on profile fits and the rate of convergence of uncertainty propagation, making them of great interest for wider use in fusion experiments and modelling efforts.United States. Dept. of Energy. Office of Fusion Energy Sciences (Award DE-FC02-99ER54512)United States. Dept. of Energy. Office of Science (Contract DE-AC05-06OR23177)United States. Dept. of Energy. Office of Advanced Scientific Computing Research (Award DE-SC0007099

The physics mechanisms of the weakly coherent mode in the Alcator C-Mod Tokamak

The weakly coherent mode (WCM) in I-mode has been studied by a six-field two-fluid model based on the Braginskii equations under the BOUT++ framework for the first time. The calculations indicate that a tokamak pedestal exhibiting a WCM is linearly unstable to drift Alfven wave (DAW) instabilities and the resistive ballooning mode. The nonlinear simulation shows promising agreement with the experimental measurements of the WCM. The shape of the density spectral and location of the spectral peak of the dominant toroidal number mode n = 20 agrees with the experimental data from reflectometry. The simulated mode propagates in electron diamagnetic direction is consistent with the results from the magnetic probes in the laboratory frame, a large ratio of particle to heat diffusivity is consistent with the distinctive experimental feature of I-mode, and the value of the simulated χeat the edge is in the range of experimental errors of χefffrom the experiment. The prediction of the WCM shows that free energy is mainly provided by the electron pressure gradient, which gives guidance for pursuing future I-mode studies

Measurement of LHCD edge power deposition through modulation techniques on Alcator C-Mod

The efficiency of LHCD on Alcator C-Mod drops exponentially with line average density. At reactor relevant densities (> 1 · 1020 [m[-3 superscript]]) no measurable current is driven. While a number of causes have been suggested, no specific mechanism has been shown to be responsible for the loss of current drive at high density. Fast modulation of the LH power was used to isolate and quantify the LHCD deposition within the plasma. Measurements from these plasmas provide unique evidence for determining a root cause. Modulation of LH power in steady plasmas exhibited no correlated change in the core temperature. A correlated, prompt response in the edge suggests that the loss in efficiency is related to a edge absorption mechanism. This follows previous results which found the generation of n||-independent SOL currents. Multiple Langmuir probe array measurements of the conducted heat conclude that the lost power is deposited near the last closed flux surface. The heat flux induced by LH waves onto the outer divertor is calculated. Changes in the neutral pressure, ionization and hard X-ray emission at high density highlight the importance of the active divertor in the loss of efficiency. Results of this study implicate a mechanism which may occur over multiple passes, leading to power absorption near the LCFS

Inboard and outboard radial electric field wells in the H- and I-mode pedestal of Alcator C-Mod and poloidal variations of impurity temperature

We present inboard (HFS) and outboard (LFS) radial electric field (E[subscript r]) and impurity temperature (T[subscript z]) measurements in the I-mode and H-mode pedestal of Alcator C-Mod. These measurements reveal strong Er wells at the HFS and the LFS midplane in both regimes and clear pedestals in T[subscript z], which are of similar shape and height for the HFS and LFS. While the H-mode E[subscript r] well has a radially symmetric structure, the E[subscript r] well in I-mode is asymmetric, with a stronger ExB shear layer at the outer edge of the E[subscript r] well, near the separatrix. Comparison of HFS and LFS profiles indicates that impurity temperature and plasma potential are not simultaneously flux functions. Uncertainties in radial alignment after mapping HFS measurements along flux surfaces to the LFS do not, however, allow direct determination as to which quantity varies poloidally and to what extent. Radially aligning HFS and LFS measurements based on the T[subscript z] profiles would result in substantial inboard-outboard variations of plasma potential and electron density. Aligning HFS and LFS E[subscript r] wells instead also approximately aligns the impurity poloidal flow profiles, while resulting in a LFS impurity temperature exceeding the HFS values in the region of steepest gradients by up to 70%. Considerations based on a simplified form of total parallel momentum balance and estimates of parallel and perpendicular heat transport time scales seem to favor an approximate alignment of the E[subscript r] wells and a substantial poloidal asymmetry in impurity temperature.United States. Dept. of Energy (Cooperative Agreement DE-FC02-99ER54512)Swiss National Science Foundatio

Poloidal asymmetries in edge transport barriers

Measurements of impurities in Alcator C-Mod indicate that in the pedestal region, significant poloidal asymmetries can exist in the impurity density, ion temperature, and main ion density. In light of the observation that ion temperature and electrostatic potential are not constant on a flux surface [Theiler et al., Nucl. Fusion 54, 083017 (2014)], a technique based on total pressure conservation to align profiles measured at separate poloidal locations is presented and applied. Gyrokinetic neoclassical simulations with XGCa support the observed large poloidal variations in ion temperature and density, and that the total pressure is approximately constant on a flux surface. With the updated alignment technique, the observed in-out asymmetry in impurity density is reduced from previous publishing [Churchill et al., Nucl. Fusion 53, 122002 (2013)], but remains substantial (nz,H/nz,L∼6). Candidate asymmetry drivers are explored, showing that neither non-uniform impurity sources nor localized fluctuation-driven transport are able to explain satisfactorily the impurity density asymmetry. Since impurity density asymmetries are only present in plasmas with strong electron density gradients, and radial transport timescales become comparable to parallel transport timescales in the pedestal region, it is suggested that global transport effects relating to the strong electron density gradients in the pedestal are the main driver for the pedestal in-out impurity density asymmetry.United States. Department of Energy (DE-FC02-99ER54512)United States. Department of Energy (DE-FG02-06ER54845)United States. Department of Energy (DE-FG02-86ER53223)United States. Department of Energy (DE-AC02-09CH11466

Quasi-coherent fluctuations limiting the pedestal growth on Alcator C-Mod: experiment and modelling

Performance predictions for future fusion devices rely on an accurate model of the pedestal structure. The candidate for predictive pedestal structure is EPED, and it is imperative to test the underlying hypotheses to further gain confidence for ITER projections. Here, we present experimental work testing one of the EPED hypotheses, namely the existence of a soft limit set by microinstabilities such as the kinetic ballooning mode. This work extends recent work on Alactor C-Mod (Diallo et al 2014 Phys. Rev. Lett. 112 115001), to include detailed measurements of the edge fluctuations and comparisons of edge simulation codes and experimental observations

Correlation ECE diagnostic in Alcator C-Mod

Correlation ECE (CECE) is a diagnostic technique that allows measurement of small amplitude electron temperature, T[subscript e], fluctuations through standard cross-correlation analysis methods. In Alcator C-Mod, a new CECE diagnostic has been installed[Sung RSI 2012], and interesting phenomena have been observed in various plasma conditions. We find that local T[subscript e] fluctuations near the edge (ρ ~ 0:8) decrease across the linearto- saturated ohmic confinement transition, with fluctuations decreasing with increasing plasma density[Sung NF 2013], which occurs simultaneously with rotation reversals[Rice NF 2011]. T[subscript e] fluctuations are also reduced across core rotation reversals with an increase of plasma density in RF heated L-mode plasmas, which implies that the same physics related to the reduction of T[subscript e] fluctuations may be applied to both ohmic and RF heated L-mode plasmas. In I-mode plasmas, we observe the reduction of core T[subscript e] fluctuations, which indicates changes of turbulence occur not only in the pedestal region but also in the core across the L/I transition[White NF 2014]. The present CECE diagnostic system in C-Mod and these experimental results are described in this paper

High-field side scrape-off layer investigation: Plasma profiles and impurity screening behavior in near-double-null configurations

New experiments on Alcator C-Mod reveal that the favorable impurity screening characteristics of the high-field side (HFS) scrape-off layer (SOL), previously reported for single null geometries, is retained in double null configurations, despite the formation of an extremely thin SOL. In balanced double-null, nitrogen injected locally into the HFS SOL is better screened by a factor of 2.5 compared to the same injection into the low field side (LFS) SOL. This result is insensitive to plasma current and Greenwald fraction. Nitrogen injected into the HFS SOL is not as well screened (only a factor of 1.5 improvement over LFS) in unbalanced double-null discharges, when the primary divertor is in the direction of B×∇B. In this configuration, impurity ‘plume’ emission patterns indicate that an opposing E × B drift competes with the parallel impurity flow to the divertor. In balanced double-null plasmas, the dispersal pattern exhibits a dominant E × B motion. Unbalanced discharges with the primary divertor opposite the direction of B×∇B exhibit excellent HFS screening characteristics – a factor of 5 enhancement compared to LFS. These data support the idea that future tokamaks should locate all RF actuators and close-fitting wall structures on the HFS and employ near-double-null magnetic topologies, both to precisely control plasma conditions at the antenna/plasma interface and to maximally mitigate the impact of local impurity sources arising from plasma-material interactions. Keywords: Alcator C-Mod; Impurity screening; Double null; High field side scrape-off layerUnited States. Department of Energy (Contract DE-FC02-99ER54512

Clostridium difficile ribotype diversity at six health care institutions in the United States

Capillary-based PCR ribotyping was used to quantify the presence/absence and relative abundance of 98 Clostridium difficile ribotypes from clinical cases of disease at health care institutions in six states of the United States. Regionally important ribotypes were identified, and institutions in close proximity did not necessarily share more ribotype diversity than institutions that were farther apart