A Comparison of the New U.S. Expatriation Tax and the Canadian Departure Tax

The Heroes Earnings Assistance and Relief Tax Act of 2008 amended the anti-avoidance provisions of the Internal Revenue Code for an expatriating taxpayer. The new law requires expatriating taxpayers to report a deemed taxable sale and repurchase of assets at the time that they expatriate. This is a change from the prior law where an expatriating taxpayer could be taxed by the U.S. for ten years after expatriation. The new U.S. rules are similar to rules that have been used by Canada to tax expatriating Canadian residents. This paper sets out the new U.S. rules and compares them to the Canadian departure tax. As can be seen, there are a number of similarities between the two countries’ laws. However, there are also some major differences. The U.S. rules are more limited in application than the Canadian rules. As well as income tax, the U.S. legislators are concerned with estate and gift taxes, whereas the Canadian legislators are not

Positioning And Design Recommendations For Materials Of Efficient Thermal Storage Mass In Passive Buildings

The role of mass in energy storage has long been a subject of interest in passive buildings. Thermal mass is used to diminish temperature variations for interior spaces in desert or semi- desert climates. Energy from solar and internal gains during the day in winter is often greater than daytime heating requirements. This energy can be stored in materials within the building, and released at night to offset building heat loss. In a similar manner, building mass may allow the interior to remain cooler during the daytime in summer and reduce air conditioning requirements. In this paper, the geometric and energetic positioning of thermal mass has been studied in order to determine most convenient locations. It is found that floors receive direct solar energy for a high percentage of time, usually 70%-90% of the radiation transmitted through the window during the day (9 am to 3 pm solar time). The materials related to the technical efficiency of thermal mass are reviewed specifying the thickness most suitable for storing solar heat in the winter or keeping the interior cool in summer.Fil: Esteves, Alfredo. Consejo Nacional de Investigaciones Científicas y Técnicas. Centro Científico Tecnológico Conicet - Mendoza. Instituto de Ambiente, Habitat y Energia.; ArgentinaFil: Mercado, Ma. Victoria. Consejo Nacional de Investigaciones Científicas y Técnicas. Centro Científico Tecnológico Conicet - Mendoza. Instituto de Ambiente, Habitat y Energia.; ArgentinaFil: Ganem, Carolina. Consejo Nacional de Investigaciones Científicas y Técnicas. Centro Científico Tecnológico Conicet - Mendoza. Instituto de Ambiente, Habitat y Energia.; Argentina. Universidad Nacional de Cuyo. Facultad de Artes y Diseño; ArgentinaFil: Gelardi, Daniel. Universidad de Mendoza. Instituto Para El Estudio del Medio Ambiente; Argentin

Value added tax and consumer spending: A graphical description analysis

The US has been considering introducing a National Consumption Tax federally. This would be in addition to the states’ sales taxes. Since a consumption tax would be an added cost to the consumer, it would be expected that there could be some behavioral change by consumers. This paper uses graphs to describe and analyze whether consumers in the UK and Canada altered their behavior when those countries introduced their Value Added Tax (or Goods and Services Tax). Both retail volume and the percentage change from the prior year (on a monthly basis) were used in the graphic depictions. It was found that there was no or little major behavioral change when the new taxes were introduced. However, when the tax rates were changed substantially, consumers did adapt their behavior to take advantage of the changes by engaging in arbitrage behavior. US consumers are likely to act in a similar manner as UK and Canadian consumers

The new United Kingdom statutory residence rules

With the global economy, many US executives are sent to the United Kingdom (UK) and/or other parts for Europe to work for short-term or long-term assignments. Even if based in the United States or continental Europe, executives of global corporations can often work in the UK. These executives can be resident in more than one country under the tax laws of each country in which the executive works. Since the UK taxes persons who are resident in the UK, it is important to ascertain whether the executive is so resident under UK law. Before April 6, 2013 there was no statutory definition of residence in the United Kingdom (UK). Much of the practical definition came from the courts and the government’s publications. There were generally two definitions; ‘resident’ and ‘ordinary resident’. At this time a major tax case, the Gaines-Cooper case, was going through the courts eventually being finally decided in the Supreme Court. It was generally considered that this case gave the impetus to the government to clarify the definition of resident by statute. This statute was the Finance Act 2013 (FA 2013). Section 218 and Schedule 45 FA 2013 set out the new statuary rules for a taxpayer. This paper explains the new rule in detail

29Si Hyperfine Structure of the E'_\alpha Center in Amorphous Silicon Dioxide

We report a study by electron paramagnetic resonance (EPR) on the E'_\alpha point defect in amorphous silicon dioxide (a-SiO2). Our experiments were performed on gamma-ray irradiated oxygen-deficient materials and pointed out that the 29Si hyperfine structure of the E'_alpha consists in a pair of lines split by 49 mT. On the basis of the experimental results a microscopic model is proposed for the E'_alpha center, consisting in a hole trapped in an oxygen vacancy with the unpaired electron sp3 orbital pointing away from the vacancy in a back-projected configuration and interacting with an extra oxygen atom of the a-SiO2 matrix.Comment: 4 page

Value added tax and inflation: A graphical and statistical analysis

The US has been considering introducing a National Consumption Tax federally. This would be in addition to the states’ sales taxes. Since a consumption tax would be an added cost to the consumer, it would be expected that inflation would be increased. This paper uses graphs and statistical methods to ascertain whether inflation in the UK and Canada was affected by the introduction or change in rate of the Value Added Tax (or Goods and Services Tax). It was found that the introduction of a VAT in the UK showed no significant effect on the rate of change of CPI, whereas the introduction of GST in Canada did have a significant increase in the rate of CPI. It was also found that when the tax rates were changed substantially, inflation was affected; however, modest changes in the tax rate did not affect inflation

Ain\u27t Nothing Like the Real Thing: Enforcing Land Use Restrictions on Land and Water Conservation Fund Parks

Congress created the Land and Water Conservation Fund (LWCF) in 1965 to provide resources for states and federal agencies to acquire and develop land for public outdoor recreation. Over the past forty years, the LWCF has quietly become one of the most successful conservation programs in United States history. The federal government and states have used the LWCF to preserve unique landscapes for their natural beauty, scientific value, and wildlife habitat, as well as to encourage traditional recreational pursuits. The LWCF Act prohibits the conversion of LWCF-funded state and local parks to uses other than public outdoor recreation unless approved by the National Park Service under strict conditions. Nevertheless, state and local LWCF grantees have illegally converted numerous LWCF parks. As pressure grows on state and local governments to develop parkland for nonrecreational uses, illegal LWCF park conversions threaten unique landscapes and the integrity of the LWCF program. This Comment argues that federal common law and statutory rights in LWCF-funded lands enable the United States to seek an array of coercive remedies to prevent, remedy, and deter illegal conversions of LWCF parks