The Declining Allure of Being “American” and the Proliferation of Corporate Tax Inversions: A Critical Analysis of Regulatory Efforts to Curtail the Inversion Trend

In the realm of tax policy, within which there is rarely broad-based consensus, there are few topics as polarizing as corporate tax inversions. An inversion is a paper transaction in which a US corporation reincorporates abroad to realize strategic tax benefits, without actually transplanting its operations overseas. These transactions necessarily reduce the US corporate income tax base, because although an inverted corporation is still taxed the same amount on income earned within the United States, it will no longer have to remit tax payments to the US Department of the Treasury (“Treasury”) for income earned abroad. This reduction in the tax base is especially troubling given that the national debt exceeds $19 trillion, the US credit rating is experiencing unprecedented volatility, and the annual US government deficit ranges from hundreds of billions to more than a trillion dollars per year. Given the current state of the domestic economy, the notion of successful US corporations nominally moving their headquarters abroad to alleviate their tax burden is unpalatable for many. Others do not fault inverters for acting in the interests of their shareholders, and simply see the trend as evidence of the need for substantial corporate tax reform so that the United States can become more globally competitive as a home for businesses. However, those with opposing viewpoints may be closer together than they realize, and meaningful reform may be attainable if productive dialogue can be facilitated. This Note provides an overview of trends in corporate taxation, the thirty-year history of inversions and governmental attempts to contain them, and an analysis of recent anti-inversion regulations proposed by Treasury in September 2014. Finally, this Note critiques the legislative and regulatory framework that attempts to restrict the practice of inversions, and provides a suggestion for constructively responding to the trend. Given the passion and diversity of viewpoints on the issue, arriving at a national consensus on how to respond to the recent proliferation of inversions presents an extraordinary challenge. There may, however, be enough common ground for lawmakers to craft a solution that removes the incentive for corporations to invert, thereby shoring up the tax base and making the US economy more competitive globally. In light of the substantial—and rapidly growing—national debt, there is no better time to critically reevaluate the policies and priorities of corporate taxation

Effect of vessel wettability on the foamability of "ideal" surfactants and "real-world" beer heads

The ability to tailor the foaming properties of a solution by controlling its chemical composition is highly desirable and has been the subject of extensive research driven by a range of applications. However, the control of foams by varying the wettability of the foaming vessel has been less widely reported. This work investigates the effect of the wettability of the side walls of vessels used for the in situ generation of foam by shaking aqueous solutions of three different types of model surfactant systems (non-ionic, anionic and cationic surfactants) along with four different beers (Guinness Original, Banks’s Bitter, Bass No 1 and Harvest Pale). We found that hydrophilic vials increased the foamability only for the three model systems but increased foam stability for all foams except the model cationic system. We then compared stability of beer foams produced by shaking and pouring and demonstrated weak qualitative agreement between both foam methods. We also showed how wettability of the glass controls bubble nucleation for beers and champagne and used this effect to control exactly where bubbles form using simple wettability patterns

Change and continuity in twentieth century America: the 1920's

(print) ix, 456 p. ; 22 cm1919 : PRELUDE TO NORMALCY David Burner 3 -- OIL AND POLITICS Burl Noggle 33 -- THE FARMERS' DILEMMA, 1919-1929 Gilbert C. Fite 67 -- LABOR IN ECLIPSE Mark Perlman 103 -- THE RISE AND DECLINE OF WELFARE CAPITALISM David Brody 147 -- THE FUNDAMENTALIST DEFENSE OF THE FAITH Paul A. Carter 179 -- THE KU KLUX KLAN Robert Moats Miller 215 -- PROHIBITION : THE IMPACT OF POLITICAL UTOPIANISM Joseph R. Gusfield 257 -- FICTION OF THE JAZZ AGE Frederick J. Hoffman 309 -- THE REVOLUTION IN MORALS Gilman M. Ostrander 323 -- THE NEW PSYCHOLOGY : FROM NARCISSISM TO SOCIAL CONTROL John Chynoweth Burnham 351 -- METROPOLIS AND SUBURB : THE CHANGING AMERICAN CITY Charles N. Glaab 399 -- NOTES ON THE CONTRIBUTORS 439 -- INDEX 44

Twentieth-century American foreign policy

(print) ix, 567 p. ; 22 cmIntroduction vii -- The Changing Interpretive Structure Of American Foreign Policy Charles E. Neu 1 -- Writings On American Foreign Relations : 1957 To The Present David F. Trask 58 -- Bureaucracy And Professionalism In The Development Of American Career Diplomacy Waldo H. Heinrichs, Jr. 119 -- The United States A World Power, 1900-1917 : Myth Or Reality? Paul A. Varg 207 -- The United States And The Failure Of Collective Security In The 1930s Manfred Jonas 241 -- The United States And The Atlantic Alliance : The First Generation Lawrence S. Kaplan 294 -- Canada In North America Robert Craig Brown 343 -- Recent United States-Mexican Relations : Problems Old And New Lyle C. Brown And James W. Wilkie 378 -- The United States And Cuba : The Uncomfortable "Abrazo," 1898-1968 Allan R. Millett 420 -- The United States And Great Britain : Uneasy Allies A. E. Campbell 471 -- From Contempt To Containment : Cycles In American Attitudes Toward China Warren I. Cohen 502 -- Notes On The Contributors 560 -- Index 56

Change and continuity in twentieth-century America

(print) 287 pThe Emergence Of America As A World Power : Some Second Thoughts Richard W. Leopold 3 -- The Square Deal In Action : A Case Study In The Growth Of The "National Police Power" John Braeman 35 -- The New Deal And The Analogue Of War William E. Leuchtenburg 81 -- The Great Depression : Another Watershed In American History? Richard S. Kirkendall 145 -- Continuity And Change In Government-Business Relations Arthur M. Johnson 191 -- The Emergence Of Mass-Production Unionism David Brody 221 -- Poverty In Perspective Robert H. Bremner 263 -- Notes On The Contributors 281 -- Index 28

'If You Desire to Enjoy Life, Avoid Unpunctual People': Women, Timetabling and Domestic Advice, 1850–1910

In the second half of the nineteenth century domestic advice manuals applied the language of modern, public time management to the private sphere. This article uses domestic advice and cookery books, including Isabella Beeton's Book of Household Management, to argue that women in the home operated within multiple, overlapping temporalities that incorporated daily, annual, linear and cyclical scales. I examine how seasonal and annual timescales coexisted with the ticking clock of daily time as a framework within which women were instructed to organize their lives in order to conclude that the increasing concern of advice writers with matters of timekeeping and punctuality towards the end of the nineteenth century indicates not the triumph of 'clock time' but rather its failure to overturn other ways of thinking about and using time

Building the Future Therapies for Down Syndrome:The Third International Conference of the T21 Research Society

Research focused on Down syndrome has increased in the last several years to advance understanding of the consequences of trisomy 21 (T21) on molecular and cellular processes and, ultimately, on individuals with Down syndrome. The Trisomy 21 Research Society (T21RS) is the premier scientific organization for researchers and clinicians studying Down syndrome. The Third International Conference of T21RS, held June 6-9, 2019, in Barcelona, Spain, brought together 429 scientists, families, and industry representatives to share the latest discoveries on underlying cellular and molecular mechanisms of T21, define cognitive and behavioral challenges and better understand comorbidities associated with Down syndrome, including Alzheimer's disease and leukemia. Presentation of cutting-edge results in neuroscience, neurology, model systems, psychology, cancer, biomarkers and molecular and phar-ma-cological therapeutic approaches demonstrate the compelling interest and continuing advancement in all aspects of understanding and ameliorating conditions associated with T21

Finishing the euchromatic sequence of the human genome

The sequence of the human genome encodes the genetic instructions for human physiology, as well as rich information about human evolution. In 2001, the International Human Genome Sequencing Consortium reported a draft sequence of the euchromatic portion of the human genome. Since then, the international collaboration has worked to convert this draft into a genome sequence with high accuracy and nearly complete coverage. Here, we report the result of this finishing process. The current genome sequence (Build 35) contains 2.85 billion nucleotides interrupted by only 341 gaps. It covers ∼99% of the euchromatic genome and is accurate to an error rate of ∼1 event per 100,000 bases. Many of the remaining euchromatic gaps are associated with segmental duplications and will require focused work with new methods. The near-complete sequence, the first for a vertebrate, greatly improves the precision of biological analyses of the human genome including studies of gene number, birth and death. Notably, the human enome seems to encode only 20,000-25,000 protein-coding genes. The genome sequence reported here should serve as a firm foundation for biomedical research in the decades ahead

The perceptions of the campus administrators' role in the prereferral processes related to the placement of African American students in special education

textAfrican American students represent 14.8% of the school population yet 20.2% of the students identified and placed in special education (U.S. Department of Education, 2000). Those identified with education-related disabilities have difficult experiences during their school career that negatively impact their later employment (Osher & Hanley, 1995). The management of special education has shifted to campus administrators without specialized knowledge to handle the task; yet they have direct responsibility to ensure that all students, including African Americans, are properly identified and placed in the appropriate educational setting (Bateman & Bateman, 2001; Ford, 2001). The campus administrators’ role prior to referral to special education may be vital in reducing the disproportionate representation of African American students in special education. This study investigated perceptions held by campus administrators, general education teachers, and a district special education specialist relative to (a) the campus administrators’ responsibility to assure there is not disproportionate identification of African American students identified for special education, (b) the campus administrators’ involvement in regular education activities prior to referral for special education, and (c) the criteria of successful regular education activities prior to referral for special education. Additionally, this study revealed campus administrators’ perceptions of knowledge and skills needed to administer effectively activities prior to referral to special education. This qualitative case study utilized a descriptive methodology involving interviews with participants directly involved in activities prior to referral to special education at multiple sites across three levels within a Texas public school district. The study revealed that campus administrators and teachers perceived the campus administrator’s role of involvement as providing teachers with resources. An important finding was that campus administrators had a limited knowledge of special education, yet providing such resources was identified as a vital part of the administrator’s role. Therefore, there is a clear disconnect between campus administrator’s perception of their role and their perception of their own knowledge and skills. Two criteria were identified for successful regular education activities prior to referral to special education: (a) to identify the needs of students and (b) to utilize school staff expertise in the process.Educational Administratio