A concise, tightly-edited casebook that focuses on core principles and policies so students can learn the major patterns and themes of corporate taxation. Features: Focuses student attention on core principles and policies to enable students to learn the major patterns and themes of corporate tax Encourages students to learn the law from the basic source material --the Code and regulations--as supplemented by concise explanations when needed Many problems, questions, and examples help lead students through the challenging material An organizational structure that bridges concepts learned in the introductory income tax course and those presented in advanced tax classes. The text begins with subchapter S--an area of growing, practical significance--which serves to link individual and separate entity taxation Presents the taxation of transactions using a ""building-block"" approach from basic to complex transactions. This approach helps students to grasp that many complex transactions are merely combinations of simpler ones, and that a given transaction may be structured in different ways to achieve different tax consequences Cases and other source materials are edited concisely and note material is kept to a manageable length Completely up-to-date. The organizational structure and text are fully integrated to reflect current developments, including codification of the economic substance doctrine; impact of corporate tax shelters and application of substance-over-form doctrine; increased importance of passthrough tax principles; comparable treatment of dividends and long-term capital gain; recent changes affecting acquisitive and divisive reorganizations; and policy implications of current corporate tax reform options
This brief presents characterizations of identification errors under a probabilistic framework when output sensors are binary, quantized, or regular. By considering both space complexity in terms of signal quantization and time complexity with respect to data window sizes, this study provides a new perspective to understand the fundamental relationship between probabilistic errors and resources, which may represent data sizes in computer usage, computational complexity in algorithms, sample sizes in statistical analysis and channel bandwidths in communications.
In view of Professor Wendell Fleming's many fundamental contributions, his profound influence on the mathematical and systems theory communi ties, his service to the profession, and his dedication to mathematics, we have invited a number of leading experts in the fields of control, optimiza tion, and stochastic systems to contribute to this volume in his honor on the occasion of his 70th birthday. These papers focus on various aspects of stochastic analysis, control theory and optimization, and applications. They include authoritative expositions and surveys as well as research papers on recent and important issues. The papers are grouped according to the following four major themes: (1) large deviations, risk sensitive and Hoc control, (2) partial differential equations and viscosity solutions, (3) stochastic control, filtering and parameter esti mation, and (4) mathematical finance and other applications. We express our deep gratitude to all of the authors for their invaluable contributions, and to the referees for their careful and timely reviews. We thank Harold Kushner for having graciously agreed to undertake the task of writing the foreword. Particular thanks go to H. Thomas Banks for his help, advice and suggestions during the entire preparation process, as well as for the generous support of the Center for Research in Scientific Computation. The assistance from the Birkhauser professional staff is also greatly appreciated.
The purchase of this ebook edition does not entitle you to receive access to the Connected eBook on CasebookConnect. You will need to purchase a new print book to get access to the full experience including: lifetime access to the online ebook with highlight, annotation, and search capabilities, plus an outline tool and other helpful resources. In this concise, tightly edited casebook, George K. Yin and Karen C. Burke emphasize core principles and policies to help students understand the overall structure and coherence of partnership taxation. The book’s organizational structure bridges concepts learned in the introductory income tax course and those presented in advanced tax courses, by offering a “building-block” approach that progresses from basic to complex partnership transactions. By emphasizing the policy choices that lend structure and coherence to the law, Partnership Taxation facilitates an understanding of the overarching principles of partnership tax. Students learn the law from basic source material—the Code and regulations—as well as tightly edited cases and other guidance. Many problems, questions, and explanations supplement the presentation to guide students through the challenging material. New to the Fourth Edition: The Fourth Edition reflects developments through February 2020, including: Expanded discussion of choice-of-entity issues in light of significant changes introduced by the 2017 tax legislation, including the 21% corporate tax rate and the section 199A passthrough deduction Revised regulations concerning allocation of partnership liabilities, including disregarded bottom-dollar payment obligations The temporary expensing deduction under section 168(k), as well as new limitations on business interest deductions and excess business losses New section 1061 imposing a three-year capital gain holding period for service partners receiving partnership interests in certain investment partnerships The revised definition of a “substantial built-in loss” under section 743(b) and repeal of the technical termination rule under section 708 Professors and students will benefit from: Approach: This book emphasizes core principles and policies to help students understand the overall structure and coherence of partnership taxation. Organization: The organizational structure bridges concepts learned in the introductory income tax course and those presented in advanced tax courses; “building-block” approach progresses from basic to complex partnership transactions. Depth: By providing in-depth coverage while avoiding unnecessary detail, the revised Fourth Edition facilitates mastery of the material and prepares students to think rigorously and creatively about the kinds of problems they will encounter as practitioners of tax and business law. Lenny faces are short character strings that describe emotions and make your text stand out.
This book presents a thorough development of the modern theory of stochastic approximation or recursive stochastic algorithms for both constrained and unconstrained problems. This second edition is a thorough revision, although the main features and structure remain unchanged. It contains many additional applications and results as well as more detailed discussion.
This book gives a systematic treatment of singularly perturbed systems that naturally arise in control and optimization, queueing networks, manufacturing systems, and financial engineering. It presents results on asymptotic expansions of solutions of Komogorov forward and backward equations, properties of functional occupation measures, exponential upper bounds, and functional limit results for Markov chains with weak and strong interactions. To bridge the gap between theory and applications, a large portion of the book is devoted to applications in controlled dynamic systems, production planning, and numerical methods for controlled Markovian systems with large-scale and complex structures in the real-world problems. This second edition has been updated throughout and includes two new chapters on asymptotic expansions of solutions for backward equations and hybrid LQG problems. The chapters on analytic and probabilistic properties of two-time-scale Markov chains have been almost completely rewritten and the notation has been streamlined and simplified. This book is written for applied mathematicians, engineers, operations researchers, and applied scientists. Selected material from the book can also be used for a one semester advanced graduate-level course in applied probability and stochastic processes.
Focusing on discrete-time-scale Markov chains, the contents of this book are an outgrowth of some of the authors' recent research. The motivation stems from existing and emerging applications in optimization and control of complex hybrid Markovian systems in manufacturing, wireless communication, and financial engineering. Much effort in this book is devoted to designing system models arising from these applications, analyzing them via analytic and probabilistic techniques, and developing feasible computational algorithms so as to reduce the inherent complexity. This book presents results including asymptotic expansions of probability vectors, structural properties of occupation measures, exponential bounds, aggregation and decomposition and associated limit processes, and interface of discrete-time and continuous-time systems. One of the salient features is that it contains a diverse range of applications on filtering, estimation, control, optimization, and Markov decision processes, and financial engineering. This book will be an important reference for researchers in the areas of applied probability, control theory, operations research, as well as for practitioners who use optimization techniques. Part of the book can also be used in a graduate course of applied probability, stochastic processes, and applications.
This book encompasses the study of hybrid switching di usion processes and their applications. The word \hybrid" signi es the coexistence of c- tinuous dynamics and discrete events, which is one of the distinct features of the processes under consideration. Much of the book is concerned with the interactions of the continuous dynamics and the discrete events. Our motivations for studying such processes originate from emerging and - isting applications in wireless communications, signal processing, queueing networks, production planning, biological systems, ecosystems, nancial engineering, and modeling, analysis, and control and optimization of lar- scale systems, under the in uence of random environments. Displaying mixture distributions, switching di usions may be described by the associated operators or by systems of stochastic di erential eq- tions together with the probability transition laws of the switching actions. We either have Markov-modulated switching di usions or processes with continuous state-dependent switching. The latter turns out to be much more challenging to deal with. Viewing the hybrid di usions as a number of di usions joined together by the switching process, they may be se- ingly not much di erent from their di usion counterpart. Nevertheless, the underlying problems become more di cult to handle, especially when the switching processes depend on continuous states. The di culty is due to the interaction of the discrete and continuous processes and the tangled and hybrid information pattern.
Metaphysical and theoretical bases of acupuncture; neuro-chemical and anatomical bases; techniques, clinical indications and speculations about future uses of electroacupuncture.
The unique (unifying) principle, called yin/yang by the ancient Chinese, is the missing key that joins religion and science, man and God, philosophy and daily life. This is George Ohsawa's first book originally published in French in 1931.
This brief treats dynamical systems that involve delays and random disturbances. The study is motivated by a wide variety of systems in real life in which random noise has to be taken into consideration and the effect of delays cannot be ignored. Concentrating on such systems that are described by functional stochastic differential equations, this work focuses on the study of large time behavior, in particular, ergodicity.This brief is written for probabilists, applied mathematicians, engineers, and scientists who need to use delay systems and functional stochastic differential equations in their work. Selected topics from the brief can also be used in a graduate level topics course in probability and stochastic processes.
This book presents recently developed methodologies that utilize quantized information in system identification and explores their potential in extending control capabilities for systems with limited sensor information or networked systems. The results of these methodologies can be applied to signal processing and control design of communication and computer networks, sensor networks, mobile agents, coordinated data fusion, remote sensing, telemedicine, and other fields in which noise-corrupted quantized data need to be processed. System Identification with Quantized Observations is an excellent resource for graduate students, systems theorists, control engineers, applied mathematicians, as well as practitioners who use identification algorithms in their work.
Contains papers based on talks given at the first AMS-IMS-SIAM Joint Summer Research Conference on Mathematics of Finance held at Snowbird. This book includes such topics as modeling, estimation, optimization, control, and risk assessment and management. It is suitable for students interested in mathematical finance.
This edited volume contains 16 research articles. It presents recent and pressing issues in stochastic processes, control theory, differential games, optimization, and their applications in finance, manufacturing, queueing networks, and climate control. One of the salient features is that the book is highly multi-disciplinary. The book is dedicated to Professor Suresh Sethi on the occasion of his 60th birthday, in view of his distinguished career.
To honor Rafail Z. Khasminskii, on his seventy-fifth birthday, for his contributions to stochastic processes and nonparametric estimation theory an IMA participating institution conference entitled "Conference on Asymptotic Analysis in Stochastic Processes, Nonparametric Estimation, and Related Problems" was held. This volume commemorates this special event. Dedicated to Professor Khasminskii, it consists of nine papers on various topics in probability and statistics.
The I Ching focuses on the belief that change is always possible, the only mistake in life is to be inflexible and not open to the opportunity of growth. It can be consulted about any situation where you desire to change an aspect of your life or your relationship with another. The I Ching seeks to make the most of any situation and to overcome the disharmony in a life. In I Ching In Plain English George Hulskramer has balanced several new translations of recently published versions of the I Ching to capture the essential spirit of this ancient classic. It opens up the meanings of the coins to a wider range of contemporary experience than is provided by Richard Wilhelm's traditionally accepted translation of 1923. The traditional Confucian version of the I Ching, which dominates Richard Wilhelm's edition, emphasises correct behaviour and good manners while the Taoist and Buddhist schools stress inner development, how to make changes to the relationships you have with people around you and how to manage change in your life. George Hulskramer's synthesis of the differing versions of the I Ching makes this edition relevant for everyone interested in this ancient oracle. The multiple meanings of each hexagram are condensed into two pages that combine Buddhist and Taoist interpretations and translations with the Confucian translations used by Wilhelm. Based on several new translations of the I Ching, this groundbreaking interpretation explores the meaning of the ancient text and places it within the context of contemporary experience. Once used for consultation and guidance, this spiritual classic has come to emphasize inner development, relationship connections, the management of daily life changes, and the balance and harmony available in philosophies and actions. This edition's condensed commentary on coins and hexagrams allows for quick and easy consultation. The I Ching focuses on the belief that change is always possible, the only mistake in life is to be inflexible and not open to the opportunity of growth. It can be consulted about any situation where you desire to change an aspect of your life or your relationship with another. The I Ching seeks to make the most of any situation and to overcome the disharmony in a life. In I Ching In Plain English George Hulskramer has balanced several new translations of recently published versions of the I Ching to capture the essential spirit of this ancient classic. His translation opens up the meanings of the coins to a wider range of contemporary experience than is provided by Richard Wilhelm's traditional translation of 1923. The multiple meanings of each hexagram are condensed into two pages that combine Buddhist and Taoist interpretations with the Confucian translations used by Wilhelm. The traditional Confucian version of the I Ching, which dominates Richard Wilhelm's edition, emphasises correct behaviour and good manners while the Taoist and Buddhist schools, which flourished before Wilhelm's visit to China in the 1920's, stress inner development, how to make changes to the relationships you have with people around you and how to manage change in your life. George Hulskramer's synthesis of the differing versions of the I Ching makes this edition relevant for everyone interested in this ancient oracle. For centuries people have consulted the I Ching, allowing themselves to be guided by it in their choices and this new translation balances the different versions of the I Ching to make this ancient oracle work for anyone. George Hulskramer has also condensed the commentary on each hexagram into two pages to allow quick and easy consultation for today's hectic world.
Little understood in the West, Tai Chi is a complete spiritual, meditational, and healing program which takes the person from the ordinary world, through the psychic, to the spiritual and beyond. It is so perfect that it even contains safe-guards to protect the person along their spiritual journey. If there was ever a spiritual discipline given to Humankind - it is Tai Chi. This book, Tai Chi The Spiritual Way, is unique in that it explains in plain English the spiritual, healing, and meditational aspects of Tai Chi. It is therefore an ideal book for those people new to Tai Chi, and those who have had more experience. Tai Chi is a form of moving meditation, healing exercise, and spiritual discipline, and this book therefore also appeals to a wide range of New Age and Alternative Therapy enquirers.
Features more than 300 authentic Chinese recipes, ranging from simple preparations to cure specific ailments to traditional "longevity banquets". The authors explain the underlying theories behind traditional Chinese beliefs about health and reconcile these ancient beliefs with Western medical knowledge about bacteria, viruses, and other causes of disease. Includes a complete fitness program on the popular Chinese qi gong exercises. 14 b&w photos.
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