The economic effects of special purpose entities on corporate tax avoidance

This study provides the first large‐sample evidence on the economic tax effects of special purpose entities (SPEs). These increasingly common organizational structures facilitate corporate tax savings by enabling sponsor‐firms to increase tax‐advantaged activities and/or enhance their tax efficiency (i.e., relative tax savings of a given activity). Using path analysis, we find that SPEs facilitate greater tax avoidance, such that an economically large amount of cash tax savings from research and development (R&D), depreciable assets, net operating loss carryforwards, intangible assets, foreign operations, and tax havens occur in conjunction with SPE use. We estimate that SPEs help generate over $330 billion of incremental cash tax savings, or roughly 6% of total U.S. federal corporate income tax collections during the sample period. Interaction analyses reveal that SPEs enhance the tax efficiency of intangibles and R&D by 61.5% to 87.5%. Overall, these findings provide economic insight into complex organizational structures supporting corporate tax avoidance.Accepted manuscrip

Evaluating the Implementation of Curriculum Development for Sustainable Design in Electrical Services Engineering

The professional role of electrical services engineers is evolving and changing to meet the needs of industry, both national and internationally. The current demands throughout the built environment are primarily driven by European Directives and Government policies pertaining to sustainable design, energy reduction and energy efficiency. Thus, it is essential that Ireland’s Higher Education Institutions meet these challenges head on by developing diverse programmes which have sustainability at the core of curriculum design. Moreover, programmes of this nature will ensure that young engineers of the future command key transferable skills and enhance their lifelong learning which is required for today’s competitive labour market. What will the engineers of the future look like – would they be recognisable from today? This pedagogical research intends to examine the development and restructuring of an existing curriculum for a level 7 degree in Sustainable Design in Electrical Services Engineering in Ireland. The programme maintains the core learning outcomes, which have been reviewed by an accreditation body, while providing engineering graduates with a host of diverse multidisciplinary skills. This curriculum development has been tailored to meet the needs of industry, but more importantly the needs and expectations of future students. How does a programme ensure students are employable? This paper offers a unique insight into engineering education as both authors are graduates of the aforementioned programme and have subsequently returned to lecture on the programme. Moreover, they have been heavily involved in the curriculum development

How are the Educational Institutes of Ireland Embracing the Paradigm Shift towards BIM?

Abstract ̶ The main objective of this paper is to evaluate how Building Information Modelling (BIM) is being implemented and embraced within Higher Education. The authors intend to examine the current delivery and aspirations of the sector. As the Irish economy faces several more years of austerity, every opportunity must be seized to make design more efficient in Architecture, Engineering and Construction. Higher Educational Institutes must respond to ensure that graduates have the skill set to support this. This paper will examine how these institutions need to migrate away from the traditional iterative design approach/process to a more collaborative holistic approach using BIM. This will involve a series of semi structured interviews of key members within educational organisations, such as Trinity College Dublin (TCD), University College Dublin (UCD) and National University of Ireland, Maynooth (NUIM). The researchers’ organisation has to date set up a new multidisciplinary school which will be viewed as part of this paper. Should there be multidisciplinary schools in all organisations? At an International level, BIM has become a critical tool for efficient and cost effective modern design. The UK is embracing this change and has mandated the use of BIM through the Government Construction Strategy”. Ireland’s educational Institutions need to embrace, what some might say is a paradigm shift towards BIM. This paper will identify what barriers currently exist which will prevent Ireland embracing this holistic shift head on

Time cost associated with sports participation for athletes with high support needs : A time-motion analysis of tasks required for para swimming

Objectives People with cerebral palsy and high support needs (CP&HSN) are profoundly inactive but also under-represented in studies evaluating physical activity interventions. Reasons for their exclusion have not been evaluated. We hypothesised that CP&HSN would be associated with high time costs of preparatory activities (eg, getting dressed/undressed), possibly contributing to low participation and under-representation. Accordingly, this pilot study aimed to: (1) evaluate whether the time required for preparatory activities was extremely different (≥3 SD) between swimmers with and without CP&HSN; and (2) provide a qualitative indication of the preparatory tasks undertaken by swimmers with CP&HSN. Methods Each of three experienced (5 years) para swimmers with CP&HSN and 20 non-disabled swimmers were timed entering and then exiting the pool on three occasions. Mean entry and exit time for each para swimmer was compared with the group mean for non-disabled swimmers, and differences of greater than 3.0 SD were considered extreme. A qualitative description of the tasks completed by the para swimmers was recorded. Results The differences in time costs between para and non-disabled swimmers met the criterion of extreme. Pool entry times for para swimmers were 8–13 times greater (Effect size = 4.1–8.7). Pool exit times were 6–10 times greater (ES=7.0–9.5). 90% of tasks completed by para swimmers required personal assistance or wheeled mobility. Conclusions This pilot study suggests that, compared with non-disabled swimmers, time costs for preparation to commence or depart training are extremely high for swimmers with CP&HSN. Further research is required to evaluate the veracity of these findings

The physical structure of radio galaxies explored with three-dimensional simulations

We present a large systematic study of hydrodynamic simulations of supersonic adiabatic jets in three dimensions to provide a definitive set of results on exploring jet density, Mach number and precession angle as variables. We restrict the set-up to non-relativistic pressure-equilibrium flows into a homogeneous environment. We first focus on the distribution and evolution of physical parameters associated with radio galaxies. We find that the jet density has limited influence on the structure for a given jet Mach number. The speed of advance varies by a small factor for jet densities between 0.1 and 0.0001 of the ambient density while the cocoon and cavity evolution change from narrow pressure balanced to wide overpressure as the ratio falls. We also find that the fraction of energy transferred to the ambient medium increases with decreasing jet–ambient density ratio, reaching ≈80 per cent. This energy is predominantly in thermal energy with almost all the remainder in ambient kinetic form. The total energy remaining in the lobe is typically under 5 per cent. We find that radio galaxies with wide transverse cocoons can be generated through slow precession at low Mach numbers. We explore a slow precession model in which the jet direction changes very slowly relative to the jet flow dynamical time. This reveals two separated bow shocks propagating into the ambient medium, one associated with the entire lobe expansion and the other with the immediate impact zone. The lobes generated are generally consistent with observations, displaying straight jets but asymmetric lobes

The Morphological Classification of Distant Radio Galaxies Explored with Three-Dimensional Simulations

We explore the observational implications of a large systematic study of high-resolution three dimensional simulations of radio galaxies driven by supersonic jets. For this fiducial study, we employ non-relativistic hydrodynamic adiabatic flows from nozzles into a constant pressure-matched environment. Synchrotron emissivity is approximated via the thermal pressure of injected material. We find that the morphological classification of a simulated radio galaxy depends significantly on several factors with increasing distance (i.e. decreasing observed resolution) and decreasing orientation often causing re-classification from FR II (limb-brightened) to FR I (limb-darkened) type. We introduce the Lobe or Limb Brightening Index (LBI) to measure the radio lobe type more precisely. The jet density also has an influence as expected with lower density leading to broader and bridged lobe morphologies as well as brighter radio jets. Hence, relating observed source type to the intrinsic jet dynamics is not straightforward. Precession of the jet direction may also be responsible for wide relaxed sources with lower LBI and FR class as well as for X-shaped and double-double structures. Helical structures are not generated because the precession is usually too slow. We conclude that distant radio galaxies could appear systematically more limb-darkened due to merger-related re-direction and precession as well as due to the resolution limitation

DELIVERING ERP LEARNING TO STUDENTS IN A UNIVERSITY BUSINESS PROGRAM

ABSTRACT In years past, Information Technology (IT