Orbit Transfer Rocket Engine Technology Program: Advanced engine study, task D.1/D.3

Concepts for space maintainability of OTV engines were examined. An engine design was developed which was driven by space maintenance requirements and by a failure mode and effects (FME) analysis. Modularity within the engine was shown to offer cost benefits and improved space maintenance capabilities. Space operable disconnects were conceptualized for both engine change-out and for module replacement. Through FME mitigation the modules were conceptualized to contain the least reliable and most often replaced engine components. A preliminary space maintenance plan was developed around a controls and condition monitoring system using advanced sensors, controls, and condition monitoring concepts. A complete engine layout was prepared satisfying current vehicle requirements and utilizing projected component advanced technologies. A technology plan for developing the required technology was assembled

Orbit transfer rocket engine technology program. Phase 2: Advanced engine study

In Phase 2 of the Advanced Engine Study, the Failure Modes and Effects Analysis (FMEA) maintenance-driven engine design, preliminary maintenance plan, and concept for space operable disconnects generated in Phase 1 were further developed. Based on the results of the vehicle contractors Orbit Transfer Vehicle (OTV) Concept Definition and System Analysis Phase A studies, minor revisions to the engine design were made. Additional refinements in the engine design were identified through further engine concept studies. These included an updated engine balance incorporating experimental heat transfer data from the Enhanced Heat Load Thrust Chamber Study and a Rao optimum nozzle contour. The preliminary maintenance plan of Phase 1 was further developed through additional studies. These included a compilation of critical component lives and life limiters and a review of the Space Shuttle Main Engine (SSME) operations and maintenance manual in order to begin outlining the overall maintenance procedures for the Orbit Transfer Vehicle Engine and identifying technology requirements for streamlining space-based operations. Phase 2 efforts also provided further definition to the advanced fluid coupling devices including the selection and preliminary design of a preferred concept and a preliminary test plan for its further development

Interest Allocation Rules, Financing Patterns, and the Operations of U.S. Multinationals

This paper examines the impact of the 1986 change in U.S. interest allocation rules on the investment and financing decisions of American multinationals. The 1986 change reduced the tax deductibility of the interest expenses of firms with excess foreign tax credits. The resulting increase in the cost of debt gives firms incentives to substitute away from using debt finance. Furthermore, to the extent that perfect financing substitutes are not available, the overall cost of capital rises as well. The empirical tests indicate that the loss of tax deductibility of parent-company interest expenses appears to reduce significantly borrowing and investing by firms with excess foreign tax credits. The same firms tend to undertake new lease commitments, which may reflect the use of leases as alternatives to capital ownership. In addition, firms affected by the tax change tend to scale back the scope of their foreign and total operations. These results are consistent with the hypothesis that firms substitute away from debt when debt becomes more expensive, and also with the hypothesis that the loss of interest tax shields increases a firm's cost of capital.

Expectations and Expatriations: Tracing the Causes and Consequences of Corporate Inversions

This paper investigates the determinants of corporate expatriations. American corporations that seek to avoid U.S. taxes on their foreign incomes can do so by becoming foreign corporations, typically by 'inverting' the corporate structure, so that the foreign subsidiary becomes the parent company and U.S. parent company becomes a subsidiary. Three types of evidence are considered in order to understand this rapidly growing practice. First, an analysis of the market reaction to Stanley Works's expatriation decision implies that market participants expect its foreign inversion to be accompanied by a reduction in tax liabilities on U.S. source income, since savings associated with the taxation of foreign income alone cannot account for the changed valuations. Second, statistical evidence indicates that large firms, those with extensive foreign assets, and those with considerable debt are the most likely to expatriate - suggesting that U.S. taxation of foreign income, including the interest expense allocation rules, significantly affect inversions. Third, share prices rise by an average of 1.7 percent in response to expatriation announcements. Ten percent higher leverage ratios are associated with 0.7 percent greater market reactions to expatriations, reflecting the benefit of avoiding the U.S. rules concerning interest expense allocation. Shares of inverting companies typically stand at only 88 percent of their average values of the previous year, and every ten percent of prior share price appreciation is associated with 1.1 percent greater market reaction to an inversion announcement. Taken together, these patterns suggest that managers maximize shareholder wealth rather than share prices, avoiding expatriations unless future tax savings - including reduced costs of repatriation taxes and expense allocation, and the benefits of enhanced worldwide tax planning opportunities - more than compensate for current capital gains tax liabilities.

Foreign Direct Investment in a World of Multiple Taxes

While governments have multiple tax instruments available to them, studies of the effect of tax policy on the locational decisions of multinationals typically focus exclusively on host country corporate income tax rates and their interaction with home country tax rules. This paper examines the impact of indirect (non-income) taxes on the location and character of foreign direct investment by American multinational firms. Indirect tax burdens significantly exceed foreign income tax obligations for these firms and appear to influence strongly their behavior. The influence of indirect taxes is shown to be partly attributable to the inability of American investors to claim foreign tax credits for indirect tax payments. Estimates imply that 10 percent higher indirect tax rates are associated with 9.2 percent lower reported income of American affiliates and 8.6 percent lower capital/labor ratios. These estimates carry implications for efficient tradeoffs between direct and indirect taxation in raising revenue while attracting mobile capital.

NMR Knight shifts and linewidths in the Ni‐Pd‐P and Ni‐Pt‐P metallic glasses: Composition and temperature dependences

NMR Knight shift and linewidth measurements are reported for the ^(31)P nuclei in the metallic glasses (Ni_(0.50)Pd_(0.50))100−_xP_x (where x=16 to 26.5) and (Ni_yPd_(1−y))_(80)P_(20) (where y=0.20 to 0.80), and both the ^(31)P and 195Pt nuclei in the metallic glass (Ni_yPt_(1−y))_(75)P_(25) (where y=0.20 to 0.68). The results are discussed in terms of the amorphous structure, electronic structure, and stability of transition metal + metalloid metallic glasses

Numerical study of the hard-core Bose-Hubbard Model on an Infinite Square Lattice

We present a study of the hard-core Bose-Hubbard model at zero temperature on an infinite square lattice using the infinite Projected Entangled Pair State algorithm [Jordan et al., Phys. Rev. Lett. 101, 250602 (2008)]. Throughout the whole phase diagram our values for the ground state energy, particle density and condensate fraction accurately reproduce those previously obtained by other methods. We also explore ground state entanglement, compute two-point correlators and conduct a fidelity-based analysis of the phase diagram. Furthermore, for illustrative purposes we simulate the response of the system when a perturbation is suddenly added to the Hamiltonian.Comment: 8 pages, 6 figure

Economic Effects of Regional Tax Havens

How does the opportunity to use tax havens influence economic activity in nearby non-haven countries? Analysis of affiliate-level data indicates that American multinational firms use tax haven affiliates to reallocate taxable income away from high-tax jurisdictions and to defer home country taxes on foreign income. Ownership of tax haven affiliates is associated with reduced tax payments by nearby non-haven affiliates, the size of the effect being equivalent to a 20.8 percent tax rate reduction. The evidence also indicates that use of tax havens indirectly stimulates the growth of operations in non-haven countries in the same region. A one percent greater likelihood of establishing a tax haven affiliate is associated with 0.5 to 0.7 percent greater sales and investment growth by non-haven affiliates, implying a complementary relationship between haven and non-haven activity. The ability to avoid taxes by using tax haven affiliates therefore appears to facilitate economic activity in non-haven countries within regions.

Pinpointing the Position of the Post-AGB Star at the Core of RAFGL 2688 using Polarimetric Imaging with NICMOS

We have used infrared polarimetric imaging with NICMOS to determine precisely the position of the star that illuminates (and presumably generated) the bipolar, pre-planetary reflection nebula RAFGL 2688 (the Egg Nebula). The polarimetric data pinpoint the illuminating star, which is not detected directly at wavelengths less than or equal to 2 microns, at a position well within the dark lane that bisects the nebula, 0.55" (about 550 AU) southwest of the infrared peak which was previously detected at the southern tip of the northern polar lobe. The inferred position of the central star corresponds to the geometric center of the tips of the four principle lobes of near-infrared H2 emission; identifying the central star at this position also reveals the strong point symmetric structure of the nebula, as seen both in the intensity and polarization structure of the polar lobes. The polarimetric and imaging data indicate that the infrared peak directly detected in the NICMOS images is a self-luminous source and, therefore, is most likely a distant binary companion to the illuminating star. Although present theory predicts that bipolar structure in pre-planetary and planetary nebulae is a consequence of binary star evolution, the separation between the components of the RAFGL 2688 binary system, as deduced from these observations, is much too large for the presence of the infrared companion to have influenced the structure of the RAFGL 2688 nebula.Comment: 15 pages, 6 figures, to appear in The Astrophysical Journa