Do Repatriation Taxes Matter? Evidence from the Tax Returns of U.S. Multinationals

An open question in the literature on the taxation of multinational corporations is whether repatriation taxes influence whether the profits of foreign subsidiaries are repatriated or reinvested abroad. Theoretical models suggest that dividend remittances should not be influenced by repatriation taxes. The results of recent empirical work indicate that dividend remittances are sensitive to repatriation taxes. This paper investigates whether the empirical evidence can be reconciled with the theoretical results by recognizing that repatriation taxes on dividends may vary over time and provide firms with an incentive to time repatriations so that they occur in years when repatriation tax rates are relatively low. We use information about cross-country differences in tax rates to separately estimate the influence of permanent tax changes, as would occur due to changes in statutory tax rates, and transitory tax changes on dividend repatriations. Our data contains U.S. tax return information for a large sample of U.S. corporations and their foreign subsidiaries. We find that the permanent tax price effect is significantly different from the transitory price effect and is not significantly different from zero, while the transitory tax price effect is negative and significant. This suggests that repatriation taxes do affect dividend repatriation behavior but only to the extent that they vary over time. Previous empirical work has apparently measured the effect of timing behavior.

Fax/Modem Capabilities; Technology Alert, August 1994

https://egrove.olemiss.edu/aicpa_news/2852/thumbnail.jp

Balanced Justice: Mr. Justice Powell and the Constitution

In his first five years on the United States Supreme Court, Justice Lewis F. Powell, Jr. has become and will most likely continue to be a leading force in shaping the direction of the Court. In many areas, Justice Powell\u27s desire for judicial flexibility as well as judicial restraint has made him a leader in turning the Burger Court away from the bright-line tests enunciated by the Warren Court. However, where the Warren Court had been flexible, Justice Powell has usually preserved this flexibility and expanded it if possible. The tool consistently utilized to achieve this flexibility has been a balancing formula that has sought to accommodate all the competing interests

An Evaluation of The Effectiveness of Adaptive Histogram Equalization for Contrast Enhancement

Adaptive Histogram Equalization (AHE), a method of contrast enhancement which is sensitive to local spatial information in an image, has been proposed as a solution to the problem of the inability of ordinary display devices to depict the full dynamic intensity range in some medical images. This method is automatic, reproducible, and simultaneously displays most of the information contained in the grey-scale contrast of the image. However, it has not been known whether the use of AHE causes the loss of diagnostic information relative to the commonly-used method intensity windowing. In the current work, AHE and intensity windowing are compared using psychophysical observer studies. In studies performed at North Carolina Memorial Hospital, experienced radiologists were shown clinical CT images of the chest. Into some of the images, appropriate artificial lesion were introduced; the physicians were then shown the images processed with both AHE and intensity windowing. They were asked to assess the probability that as given image contained the artificial lesion, and their accurate was measured. The results of these experiments shown that for this particular diagnostic task, there was no significant difference in the ability of the two methods to depict luminance contrast; thus, further evaluation of AHE using controlled clinical trials is indicated

Distributed Branching Bisimulation Minimization by Inductive Signatures

We present a new distributed algorithm for state space minimization modulo branching bisimulation. Like its predecessor it uses signatures for refinement, but the refinement process and the signatures have been optimized to exploit the fact that the input graph contains no tau-loops. The optimization in the refinement process is meant to reduce both the number of iterations needed and the memory requirements. In the former case we cannot prove that there is an improvement, but our experiments show that in many cases the number of iterations is smaller. In the latter case, we can prove that the worst case memory use of the new algorithm is linear in the size of the state space, whereas the old algorithm has a quadratic upper bound. The paper includes a proof of correctness of the new algorithm and the results of a number of experiments that compare the performance of the old and the new algorithms

Assessment of the Effects of High-Speed Aircraft in the Stratosphere: 1998

This report assesses the potential atmospheric impacts of a proposed fleet of high-speed civil transport (HSCT) aircraft. The purpose of the report is to assess the effects of HSCT's on atmospheric composition and climate in order to provide a scientific basis for making technical, commercial, and environmental policy decisions regarding the HSCT fleet. The work summarized here was carried out as part of NASA's Atmospheric Effects of Aviation Project (a component of the High-Speed Research Program) as well as other NASA, U.S., and international research programs. The principal focus is on change in stratospheric ozone concentrations. The impact on climate change is also a concern. The report describes progress in understanding atmospheric processes, the current state of understanding of HSCT emissions, numerical model predictions of HSCT impacts, the principal uncertainties in atmospheric predictions, and the associated sensitivities in predicted effects of HSCT'S

Global data for ecology and epidemiology: a novel algorithm for temporal Fourier processing MODIS data

Background. Remotely-sensed environmental data from earth-orbiting satellites are increasingly used to model the distribution and abundance of both plant and animal species, especially those of economic or conservation importance. Time series of data from the MODerate-resolution Imaging Spectroradiometer (MODIS) sensors on-board NASA's Terra and Aqua satellites offer the potential to capture environmental thermal and vegetation seasonality, through temporal Fourier analysis, more accurately than was previously possible using the NOAA Advanced Very High Resolution Radiometer (AVHRR) sensor data. MODIS data are composited over 8- or 16-day time intervals that pose unique problems for temporal Fourier analysis. Applying standard techniques to MODIS data can introduce errors of up to 30% in the estimation of the amplitudes and phases of the Fourier harmonics. Methodology/Principal Findings. We present a novel spline-based algorithm that overcomes the processing problems of composited MODIS data. The algorithm is tested on artificial data generated using randomly selected values of both amplitudes and phases, and provides an accurate estimate of the input variables under all conditions. The algorithm was then applied to produce layers that capture the seasonality in MODIS data for the period from 2001 to 2005. Conclusions/Significance. Global temporal Fourier processed images of 1 km MODIS data for Middle Infrared Reflectance, day- and night-time Land Surface Temperature (LST), Normalised Difference Vegetation Index (NDVI), and Enhanced Vegetation Index (EVI) are presented for ecological and epidemiological applications. The finer spatial and temporal resolution, combined with the greater geolocational and spectral accuracy of the MODIS instruments, compared with previous multi-temporal data sets, mean that these data may be used with greater confidence in species' distribution modelling

Salivary and lacrimal dysfunction after radioactive iodine for differentiated thyroid cancer: American Head and Neck Society Endocrine Surgery Section and Salivary Gland Section joint multidisciplinary clinical consensus statement of otolaryngology, ophthalmology, nuclear medicine and endocrinology

BackgroundPostoperative radioactive iodine (RAI) administration is widely utilized in patients with differentiated thyroid cancer. While beneficial in select patients, it is critical to recognize the potential negative sequelae of this treatment. The prevention, diagnosis, and management of the salivary and lacrimal complications of RAI exposure are addressed in this consensus statement.MethodsA multidisciplinary panel of experts was convened under the auspices of the American Head and Neck Society Endocrine Surgery and Salivary Gland Sections. Following a comprehensive literature review to assess the current best evidence, this group developed six relevant consensus recommendations.ResultsConsensus recommendations on RAI were made in the areas of patient assessment, optimal utilization, complication prevention, and complication management.ConclusionSalivary and lacrimal complications secondary to RAI exposure are common and need to be weighed when considering its use. The recommendations included in this statement provide direction for approaches to minimize and manage these complications.Peer Reviewedhttp://deepblue.lib.umich.edu/bitstream/2027.42/163491/2/hed26417.pdfhttp://deepblue.lib.umich.edu/bitstream/2027.42/163491/1/hed26417_am.pd

Characterisation of proteins in excretory/secretory products collected from salmon lice, Lepeophtheirus salmonis

Background  The salmon louse, Lepeophtheirus salmonis, is an ectoparasitic copepod which feeds on the mucus, skin and blood of salmonid fish species. The parasite can persist on the surface of the fish without any effective control being exerted by the host immune system. Other ectoparasitic invertebrates produce compounds in their saliva, excretions and/or secretions which modulate the host immune responses allowing them to remain on or in the host during development. Similarly, compounds are produced in secretions of L. salmonis which are thought to be responsible for immunomodulation of the host responses as well as other aspects of crucial host-parasite interactions.  Methods  In this study we have identified and characterised the proteins in the excretory/secretory (E/S) products of L. salmonis using LC-ESI-MS/MS.  Results  In total 187 individual proteins were identified in the E/S collected from adult lice and pre-adult sea lice. Fifty-three proteins, including 13 serine-type endopeptidases, 1 peroxidase and 5 vitellogenin-like proteins were common to both adult and pre-adult E/S products. One hundred and seven proteins were identified in the adult E/S but not in the pre-adult E/S and these included serine and cysteine-type endopeptidases, vitellogenins, sphingomyelinase and calreticulin. A total of 27 proteins were identified in pre-adult E/S products but not in adult E/S.  Conclusions  The assigned functions of these E/S products and the potential roles they play in host-parasite interaction is discussed