Issues in the Taxation of Foreign Source Income

This paper examines some aspects of the tax treatment of U.S. multinational corporations. The emphasis is on problems of coordination of the different tax systems faced by the firms. The U.S. corporate income tax must take account of the fact that the firms' over- seas income is taxed by the host governments, in a variety of ways. Currently, the foreign tax credit is the principle mechanism for making these adjustments; it is examined, along with alternative methods such as territorial treatment and a deduction for foreign taxes. The paper also considers the closely related question of coordinating measures of taxable income. The most common method, the arm's length rule, is examined. Alternatives to it, including allocation by shares and a partial case involving allocation of research and development expenses, are also considered. First, the revenue effects of these tax regimes are simulated, with no behavioral responses considered. Responses in location of investment decisions are then included. The data are taken from the corporations' U.S. tax returns, cross-tabulated into approximately 240 industry and country cells.

Clinical and Procedural Effects of Transitioning to Contact Force Guided Ablation for Atrial Fibrillation.

Background: A major innovation in atrial fibrillation (AF) ablation has been the introduction of contact force (CF) sensing catheters. Objective: To evaluate procedural and clinical effects of transitioning to CF-guided AF ablation. Methods: Consecutive AF ablation patients were studiedduring the period of time of transitioning from a non-CF to CF sensing catheter. Procedural data recorded was total radiofrequency time, time to isolate the left pulmonary veins (LPVs), and time to isolate the right pulmonary veins (RPVs). Clinically, the 3 and 12-month maintenance of sinus rhythm was noted and compared by: paroxysmal vs. persistent AF; CT scan LA volume more or less than 150 cc; CHA2DS2VASC more or less than 2; and LVEF more or less than 55%. Safety data was recorded as well. Results: Total ablation times were shorter (113 vs.146 min, p=0.011)when using the CF catheters compared to non-CF ablations. This was driven by a decrease in both LPV (46 vs.72 min, p\u3c0.001) and RPV time (54 vs. 75 min, p=0.002).The use of CF catheter did not change the overall percentage of patients in sinus rhythm at 3 and 12-months of follow up. However, sinus rhythm was more frequent at 12 months with CF ablation inpatients with an LA volume of more than 150 cc when compared to non-CF ablation (84.6% and 52.4%, p=0.03). There was no difference in outcomes with stratification by CHA2DS2VASC score or LVEF. No significant difference in complications was noted. Conclusions: For AF ablation, the initial use of CF-sensing technology reduced procedure times with similar overall sinus rhythm maintenance at 3 and 12 months. CF improved 12-month outcomes in patients with an enlarged LA

Local Government Budgeting: The Econometric Comparison of Political and Bureaucratic Models

The current paper presents a method of deciding the question of whether any given stage in the budget process is an example of the "political" or the "bureaucratic" model. We then use it to study local government spending on education. The basis for our method is the important difference between the effect of intergovernmental aid that is implied by the political budget model and by the bureaucratic budget model. According to the bureaucratic model, the effect of inter-governmental aid on each category of educational input (e.g., teachers' salaries, books, etc.) depends only on the change in total educational spending induced by the aid and not on the type of aid that causes the change in spending. In contrast, the political budget model implies that the overall expenditure increase is the result of separate decisions on each of the expenditure categories and that the changes in these expenditure categories will depend on the form of the intergovernmental aid. Our method of exploiting this difference is presented in detail below.

Taxation and the Location of U.S. Investment Abroad

Tax policy toward the overseas income of U.S. firms is an important issue since foreign investment accounts for a sizabLe fraction of total investment by U.S. firms. At present there is no consensus on the degree to which U.S. firms respond to tax incentives when making international investment decisions. This paper seeks to shed light on this issue. Because the tax systems of (at least) two countries are involved,the specification of tax incentives is far from trivial. For example, U.S.treatment is based on the foreign tax credit mechanism. In its purest form,this mechanism would insure that the net tax rate on all income of U.S. firms would be equal to the U.S. rate, rendering the tax rates in the host countries irrelevant. In fact, actual U.S. tax practice is far removed from an idealized foreign tax credit mechanism. For instance the U.S. tax is not collected until income is repatriated from abroad; section I points out that deferral changes the incentive effects in fundamental ways. Foreign income tax rates definitely do matter in theory; in fact, they may be of overriding importance.The remainder of the paper seeks to test these theoretical considerations. First,we describe the cross-section data that were collected for this purpose. Then, we report the result that U.S. firms respond to net rates of return in general and to properly specified tax rates in particular.

The Value of Implantable Cardioverter-Defibrillators in Managing Atrial Fibrillation

Atrial fibrillation (AF) is associated with an increased risk of mortality as well as significant morbidity including bothersome symptoms, exacerbation of heart failure, and thromboembolic events. Explanations for the mortality risk are variable, but the majority opinion favors AF as a marker of reduced health status, especially cardiovascular health

Sylow pp-groups of polynomial permutations on the integers mod pnp^n

We describe the Sylow $p$-groups of the group of polynomial permutations of the integers mod $p^n$

Lattice Boltzmann Magnetohydrodynamics

Lattice gas and lattice Boltzmann methods are recently developed numerical schemes for simulating a variety of physical systems. In this paper a new lattice Boltzmann model for modeling two-dimensional incompressible magnetohydrodynamics (MHD) is presented. The current model fully utilizes the flexibility of the lattice Boltzmann method in comparison with previous lattice gas and lattice Boltzmann MHD models, reducing the number of moving directions from $36$ in other models to $12$ only. To increase computational efficiency, a simple single time relaxation rule is used for collisions, which directly controls the transport coefficients. The bi-directional streaming process of the particle distribution function in this paper is similar to the original model [ H. Chen and W. H. Matthaeus, Phys. Rev. Lett., {\bf 58}, 1845(1987), S.Chen, H.Chen, D.Mart\'{\i}nez and W.H.Matthaeus, Phys. Rev. Lett. {\bf 67},3776 (1991)], but has been greatly simplified, affording simpler implementation of boundary conditions and increasing the feasibility of extension into a workable three-dimensional model. Analytical expressions for the transport coefficients are presented. Also, as example cases, numerical calculation for the Hartmann flow is performed, showing a good agreement between the theoreticalComment: 45 pages, to appear in Physics of Plasma

Commentary to: TDOA versus ATDOA for wide area multilateration system

The paper (Stefanski and Sadowski, EURASIP J. Wirel. Commun. Netw. 2018, Article 179) introduces a multilateration algorithm for unsynchronized sensor networks. However, a very similar method has been proposed before that is not cited. Furthermore, in the measurement model of Stefanski and Sadowski (EURASIP J. Wirel. Commun. Netw. 2018, Article 179), an incorrect covariance matrix (Eq. (11) in Stefanski and Sadowski (EURASIP J. Wirel. Commun. Netw. 2018, Article 179)) has been used that leads to inferior results. We summarize the context and explain the measurement methodology proposed in Stefanski and Sadowski (EURASIP J. Wirel. Commun. Netw. 2018, Article 179), while referring to the missing citation. Finally, we derive the correct covariance matrix of the measurement error and demonstrate that the covariance matrix proposed in Stefanski and Sadowski (EURASIP J. Wirel. Commun. Netw. 2018, Article 179) is incorrect