1) What is the event that marks the transition from haploid to the diploid stage of the life cycle and what event marks the transition back to the haploid stage again. Describe the timing of these two cellular even in life cycles that are dominated by haploid cells, dominated by diploid cells or that have alternation of generations.
2) What are the closest relatives of land plants? How do you know this? What do these relatives tell us about the ancestors of green plants -- where did they live? How big were they?
3) Why was it the green algae that gave rise to land plants -- why don’t we have relatives of red or brown algae living on land?
In: Biology
H.R. 1 has changed like-kind exchange treatment to allow 1031 to apply only to exchanges of real estate. Read the following article that explains the history of 1031 and lists some pros and cons of 1031 treatment.
Do you think the
changes to 1031 which were included in H.R. 1 address the concerns?
Should 1031 have been repealed entirely? Should it not have changed
at all?POINT & COUNTERPOINT To Repeal or Retain Section 1031: A
Tempest in a $6 Billion Teapot
By Bradley T. Borden, Joseph B. Darby III, Charlene D. Luke &
Roberta F. Mann* This article is a condensation and summary of the
“Lincoln–Douglas Debate on Whether to Repeal Code § 1031” held at
the Teaching Tax Committee meeting at the 2015 ABA Section of
Taxation Midyear Meeting in Houston, Texas. The debate itself was
lively and fun, and raised numerous interesting and provocative
points on both sides of the issue. The authors thank Stephen
Breitstone for filling in at the last minute to participate in the
debate. The arguments for and against repeal are presented in
article format here, but the authors are not in full agreement with
respect to each argument. To retain, repeal, or reform? These are
the questions section 1031 invites. This brief article attempts to
lay out the competing arguments in favor of each of the first two
questions and then explores the two most prominent reform
alternatives. If each of the four authors were to have individually
stated their views as to each question, readers would be faced with
twelve essays. Instead, they have combined and condensed their
argument into four parts: (1) a short history of section 1031; (2)
the arguments in favor of repeal; (3) the arguments against repeal;
and (4) potential avenues for reform.
Short History of Section 1031 The first “modern” income tax law was
adopted by Congress in 1913, and the first antecedent to section
1031 was enacted eight years later, in 1921. The original provision
was broader in scope than present-day section 1031, providing that
no gain or loss would be recognized on an exchange of property if:
(1) the property received did not have a readily realizable market
value or (2) the property transferred was held for investment or
for productive use in a trade or business and exchanged for
property of a like kind or use. The provision allowing
non-like-kind exchanges of property was soon eliminated in 1924,
and since then the like-kind exchange rules have remained
substantially intact, with the legislative tweaks described below,
for almost 100 years. The law itself was substantially unchanged
from 1924 to 1984, but during that period a significant body of
section 1031 case law developed. Perhaps most importantly, the
courts fleshed out the parameters of the section 1031 exchange
requirement. They held that multiple-party transactions could
satisfy the statutory requirement only if the exchanger was not in
actual or constructive receipt of the exchange proceeds.
Consequently, most multiple-party exchanges required a facilitator.
In response to the Ninth Circuit’s 1979 holding in Starker v.
United States that a transaction qualified as an “exchange” even
though there was a two-year gap between the transfer of the
relinquished property and the receipt of the replacement
property,
* Bradley T. Borden, Professor of Law, Brooklyn Law School,
Brooklyn, NY; Joseph B. (Jay) Darby III, Partner, Sullivan &
Worcester LLP, Boston, MA, and Adjunct Professor of Law, Boston
University School of Law; Charlene D. Luke, Professor of Law,
University of Florida Levin College of Law, Gainesville, FL; and
Roberta F. Mann, Loran L. Stewart Professor of Business Law,
University of Oregon School of Law, Eugene, OR. Note that Jay Darby
dissents from the section covering the arguments favoring repeal,
concurs in the section covering the arguments against repeal, and
concurs in part and dissents in part with respect to the section
covering potential avenues for reform.
18 I ABA SECTION OF TAXATION NEWSQUARTERLY
Congress enacted section 1031(a)(3) in 1984. That provision allows
for deferred exchanges that satisfy the identification and exchange
timing requirements. The 1984 legislation also prohibited the
application of section 1031 to exchanges of partnership interests.
In 1989, Congress added section 1031(f), limiting the benefits of
like-kind exchanges between related parties, and section 1031(h),
treating U.S. property as being not of like-kind to foreign
property. Administrative regulations and rulings have also actively
contributed to the law under section 1031. In 1991, the Service
issued extensive regulations that created exchange safe harbors,
including the qualified intermediary safe harbor, to help
exchangers more easily accomplish transactions that the Service
deemed to come within the section 1031 definition of exchange. The
Service also provided substantial guidance on how to structure
reverse exchanges, improvement exchanges, leasehold improvement
exchanges, and program exchanges with certainty that the Service
will not challenge the application of section 1031 to such
transactions. The Service also provided
specific guidance about the nature of tenancy-in-common interests
and interests in certain statutory trusts that hold real estate.
With that guidance, exchangers can be comfortable that a long-held
fee interest in real property can be like kind to an interest in a
properly structured Delaware statutory trust held by numerous other
owners throughout the country. Needless to say, the current
application of section 1031 is significantly different from its
application in 1921 when its predecessor became part of the law.
Every exchanger must report like-kind exchanges on Form 8824.
Published data from recent tax years reveals that individuals file
more than 60% of all filed Forms 8824. Corporations account for
about 30% of filed returns, but they account for almost 60% of all
reported deferred gain. The table below summarizes these numbers.
Arguments in Favor of Repealing Section 1031 An effective tax
provision should be equitably distributed, minimize economic
distortions, and be easy to administer. Section 1031 arguably fails
to meet any
of these classic tax policy criteria. It can be asserted that it
disproportionately benefits wealthy taxpayers, causes
overinvestment in qualifying property, and has created massive
administrative complexity. While section 1031 may have served a
valid purpose when first enacted, it arguably has evolved into an
entrenched, expensive, undeserved, and unnecessary benefit. Recent
Calls for Repeal In 2010, the so-called “Volker Report” presented
the repeal of section 1031 as an option for reforming the tax
treatment of capital gains. Republican Chairman of the House Ways
and Means Committee David Camp proposed repealing section 1031 in
his comprehensive tax reform discussion draft. Democratic Chairman
of the Senate Finance Committee Max Baucus proposed repealing
section 1031 in his discussion draft on tax reform of cost recovery
and accounting. President Obama’s 2015 Budget proposed limiting
section 1031 gain deferral to $1 million per taxpayer per taxable
year, which was estimated to reduce the budget deficit by an
estimated $18.27 billion over the years. News reports, such as an
article in The New York Times last January about
POINT & COUNTERPOINT I TO REPEAL OR RETAIN SECTION 1031
continued from page 1
Form 8824 Data for Tax Year 2011 (All money amounts are in
thousands of dollars)
Individuals Corporations Partnerships Number of Forms 8824 170,268
82,314 22,064 Item Line No. Amount Amount Amount FMV of other
property given up 12 $289,416 $430,345 $726,115 Adjusted basis of
other property given up 13 $68,974 $205,219 $34,677 Gain (or loss)
recognized on other property given up 14 $220,442 $225,127 $691,439
Cash received, FMV of other property received, plus net liabilities
15 $1,787,432 $1,914,721 $1,408,502 FMV of like-kind property
received 16 $15,311,387 $35,229,605 $15,107,374 Adjusted basis of
like-kind property given up 18 $12,377,383 $15,110,927 $9,198,798
Realized gain (or loss) 19 $4,721,435 $23,711,560 $10,132,650
Ordinary income under recapture rules 21 $52,829 $2,651,711
$279,086 Recognized gain 23 $849,498 $3,142,592 $918,758 Deferred
gain (or loss) 24 $3,871,938 $20,601,736 $9,213,893 Basis of
like-kind property received 25 $11,439,449 $17,114,754
$12,269,709
Source: Internal Revenue Service, Statistics of Income
Division.
SPRING 2015 I 19
major American companies “pushing the boundaries” of section 1031,
have fueled the appetite for repeal. To be sure, budget estimates
may show partisan bias, but the scope of the number utilized by the
Obama administration at least provides a sense of the maximum
expenditure represented by current law. Inequitable Distribution of
Section 1031 Benefits Section 1031 is the third largest corporate
tax expenditure, estimated to reduce revenues by $11.7 billion in
2014. Supporters of section 1031 may argue that if it is repealed,
taxpayers will simply use other strategies like investment in real
estate investment trusts, holding property in partnerships, or
cross-renting arrangements. However, these arguments do not support
retaining section 1031, although they may support reform of other
provisions. There is little data on the distributional impact of
section 1031. However, various studies show that the preferential
tax rate for capital gains disproportionately benefits the
wealthiest of taxpayers. For instance, the Congressional Budget
Office estimates that taxpayers in the top 1% receive 68% of the
benefit of low tax rates on capital gains and dividends, while the
bottom 80% will receive only 7%. As section 1031 allows tax
deferral upon the transfer of investment property that would
otherwise frequently produce capital gains for individuals, it is
likely that section 1031 benefits the same sort of taxpayer.
Section 1031 is unlikely to benefit small investors because the
gain deferral would not be enough to offset the costs of the
exchange, which generally include hiring an accommodator to
facilitate the exchange. Additionally, the transaction cost of
hiring an accommodator would be a larger percentage of the tax
benefit gain on the exchange of lower-value property. Finally, the
data from Form 8824 shows that corporations derive the greatest tax
benefit from section 1031,
suggesting that the benefit goes to the largest taxpayers.
Overinvestment in Like-Kind Property Causes Economic Distortion
Section 1031 encourages reinvestment of exchange proceeds in
property that is like kind to relinquished property. Thus, section
1031 encourages what might be called “asset-type lock-in effect.”
For instance, exchangers lock in to holding real estate, if their
initial investment was in real estate. Without section 1031, those
same investors might diversify their holdings. By encouraging
reinvestment in like-kind property, section 1031 may artificially
inflate the value of property that qualifies for section 1031
treatment. Any inflated values affect investor decisions and
further distort economic behavior. Calls for retention of section
1031 come loudest from the real estate and qualified intermediary
industries. They predict disaster and economic collapse if the prop
of section 1031 is removed. These predictions are undoubtedly
biased. The Federation of Exchange Accommodators (FEA), an industry
group representing section 1031 exchange accommodators, argued that
the Joint Committee on Taxation (JCT) estimates of revenue lost to
like-kind exchanges in 2010 were overstated, based on a survey of
their customers. JCT’s 2010 estimate of the revenue loss from
section 1031 was $2.1 billion. The actual deferred gain based on
Forms 8824 filed in 2010 was $40 billion, which, if one were to
calculate tax savings using a conservative 15% capital gains rate,
would translate to $6 billion of revenue loss. As there was likely
some recapture and higher rate capital gain in the mix, the JCT’s
estimate rather than overstating, significantly understated the
revenue loss. One argument is that even though the government loses
revenue when a property owner transfers property and exchanges up
into more expensive property, the government effectively
becomes a partner in the reinvested capital
In: Accounting
Suppose an opaque jar contains 3 red marbles and 10 green marbles. The following exercise refers to the experiment of picking two marbles from the jar without replacing the first one. What is the probability of getting a green marble first and a red marble second?
In: Statistics and Probability
Over the past two years, the unemployment rate in Country X has risen from 5 per cent to 9 percent. As the leader of country X, you have been presented with two policy options to address the unemployment problems. Policy 1: Use tariffs and quotas to restrict imports and thus protect jobs in Country X. Policy 2: Use monetary and fiscal policies to solve the unemployment problem without resorting to trade restrictions. a) Explain two disadvantages of selecting Policy 1 b) Describe in detail one specific monetary policy action and one specific fiscal policy action you would take to reduce unemployment. Explain how each of these actions would affect each of the following in the short run. I) Aggregate demand II) Output and the price level III) Real Interest rates c) If the interest rate effects you identified in Part (b) continue in the long run, explain the impact of these effects on economic growth.
In: Economics
As the article indicates, the United States is the only country among forty-one (41) industrialized nations that does not mandate paid maternity leave. What are your thoughts and impressions regarding this fact?
In your reasoned opinion, should the federal government mandate paid leave for the birth or adoption of a child? If the federal government should continue to not recognize paid family leave, should state governments? Explain your responses.
In: Economics
Directions for written assignment (about 150 words). Please answer these questions:
1. What are two of the visible impacts of the human response to the COVID-19 pandemic on the environment?
2. What are three of the "ten lessons the coronavirus has taught us about the planet"? Refer to the article: Degnarain 2020: Ten Lessons The Coronavirus Has Taught Us About The Planet
3. Which of these three do you think is the most important? Explain your reasoning.
In: Civil Engineering
Part of your role a health care professional is to learn how to be comfortable with ambiguity. this means that there will be many situation where there is no "one right answer" or way of dealing with a situation. based upon what you have read regarding critical thinking and reflection, describle a situation in which your critical thinking made you think about the situation differetly. if you have experience in the clinical area, use a situation from those experience. if not, use a situation which occurred in your personal or professional life in which you have learned to think about differently.
In: Nursing
What brain areas are associated with memory consolidation and different types of memory (declarative, procedural, working, etc)?
in detail please
What changes in the brain occur with learning?
in detail
In: Psychology
Given two graphs G = [V ; E] and G0 = [V 0 ; E0 ], and an isomorphism, f : V → V 0 , and making direct use of the formal definition for isomorphism:
(a) Explain why G and G0 must have the same number of vertices.
(b) Explain why G and G0 must have the same number of edges.
(c) Explain why G and G0 must have the same degree sequences.
(d) Given two vertices, u, v ∈ V explain why: u is connected to v → f(u) is connected to f(v)
Note: Problems that ask you to “explain” are asking for responses that can be less formal than problems that ask you to “prove”. Nonetheless, responses need to be sufficiently precise and based on definitions and theorems as given in the text. Explanations should be concise, but care must be taken to ensure that explanations are at an appropriate level of detail and will be clear to the intended reader.
In: Advanced Math
The United States Army recently commissioned a study to assess how deeply a bullet penetrates ceramic body armor. In the study, a cylindrical clay model was layered under an armor vest. A projective was then fired, causing an indentation in the clay. The deepest impression in the clay was measured as an indication of survivability of someone wearing the armor. Here are the data that were observed; measurements (Y , measured in mm) were made using a manually controlled digital caliper. The data are already ordered from low to high.
y <- c(22.4,23.6,24.0,24.9,25.5,25.6,25.8,26.1,26.4,26.7,27.4,27.6,28.3, 29.0,29.1,29.6,29.7,29.8,29.9,30.0,30.4,30.5,30.7,30.7,31.0,31.0, 31.4,31.6,31.7,31.9,31.9,32.0,32.1,32.4,32.5,32.5,32.6,32.9,33.1, 33.3,33.5,33.5,33.5,33.5,33.6,33.6,33.8,33.9,34.1,34.2,34.6,34.6, 35.0,35.2,35.2,35.4,35.4,35.4,35.5,35.7,35.8,36.0,36.0,36.0,36.1, 36.1,36.2,36.4,36.6,37.0,37.4,37.5,37.5,38.0,38.7,38.8,39.8,41.0, 42.0,42.1,44.6,48.3,55.0)
(a) Check the normal assumptions with plots. State clearly why do you use the plots and what does the plot imply.
(b) Construct a 95 percent confidence interval for the population mean µ and interpret your interval. Explain clearly (in words) what µ represents in the context of this problem.
(c) A co-worker of yours looks at your interval in part (a) and says, ”I’m confused. Ninetyfive percent of the measurements above should be in this interval, but far fewer are.” How would you respond to him?
(d) Calculate a 95 percent confidence interval for the population standard deviation σ and interpret your interval. Explain clearly (in words) what σ represents in the context of this problem.
In: Statistics and Probability