Magnetic fields & electromagnetic induction Learning outcomes Teaching challenges Permanent magnets Defining magnetic flux density

Magnetic fields & electromagnetic induction Learning outcomes Teaching challenges Permanent magnets Defining magnetic flux density www.phwiki.com

Magnetic fields & electromagnetic induction Learning outcomes Teaching challenges Permanent magnets Defining magnetic flux density

Hymer, Dian, Freelance Columnist has reference to this Academic Journal, PHwiki organized this Journal Magnetic fields & electromagnetic induction Learning outcomes describe magnetic fields in terms of magnetic flux & flux density use Fleming’s left in addition to right h in addition to rules to describe interactions between magnetic field & current quantitatively describe B fields around a straight current-carrying wire in addition to a solenoid quantitatively describe the as long as ce on a charged particle moving at right angles to a uni as long as m B field explain electromagnetic induction using Faraday’s & Lenz’s law use the concept of flux linkage to explain how trans as long as mers work describe how B fields are used in circular particle accelerators recall the postulates in addition to key consequences of special relativity solve related quantitative problems Teaching challenges fields are abstract involves 3-D thinking but generally illustrated in 2-D involves rates of change different concepts have similar names some physical quantities have a variety of equivalent units students may need simple trigonometry to find the magnetic flux, or magnetic as long as ce, correctly identifying angle .

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Permanent magnets Magnetic field lines start in addition to finish at poles. Physicists picture this as a ‘flow’ in magnetic circuit. magnetic flux (phi), unit Weber magnetic flux density B, unit Weber m-2 or Tesla Carl Gauss & Wilhelm Weber investigated geomagnetism in 1830s, made accurate measurements of magnetic declination in addition to inclination, built the first electromagnetic telegraph. Defining magnetic flux density Typical magnetic field strengths: Fleming’s left-h in addition to rule: Force on the wire is perpendicular to both l in addition to B. Electromagnetism Electric currents have loops of B flux around them. Current-turns produce flux.

Magnetic fields near currents long straight wire long solenoid, N turns in addition to length l is the permeability of free space Forces on parallel currents parallel – attract anti-parallel – repel Forces on parallel currents At the top wire in the diagram, Defining the ampere (straight wires of infinite length) If the current in each wire is exactly 1 A, in addition to the distance between the wires is 1 m, then the as long as ce on each metre length of the wires will be 2 x 10-7 N. Practice questions: TAP Forces on currents

Demonstration: fine beam tube uni as long as m B-field at right angles to an electron beam with v F is perpendicular to v, so the beam travels in a circular path. Force on a moving charge Fluxes in addition to as long as ces Michael Faraday (experimenting in 1830s at the Royal Institution) pictured magnetic field lines as flexible in addition to elastic magnetic attraction: field lines try to get shorter & straighter magnetic repulsion: field lines cannot cross Faraday’s law of induction Induced emf is proportional to rate of ‘cutting’ field lines. N is number of turns on the secondary coil. N is its flux linkage. Induced emf is proportional to rate of change in coil’s flux linkage. NOTE: Eddy currents are induced in iron core linking primary in addition to secondary coils. These can be reduced by laminations in core.

1 the flux cut by a moving wire 2 the change in flux due to a magnet moving 3 the change in flux due to a stationary electromagnet which is changing in strength No relative motion means no induced emf. Under what conditions is there an induced current can be: Experiments Force on a current-carrying wire Current balance Investigating fields near currents (using a Hall probe) Investigating electromagnetic induction Faraday’s law Jumping ring Practice questions (Adv Physics) Changes in flux linkage (Adv Physics) Flux or flux linkage TAP Rates of change (Adv Physics) Graphs of changing flux in addition to emf

Endpoints rotating coil (AC) generator: motors produce a ‘back emf’

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Hymer, Dian Freelance Columnist

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Introduction The Winter Olympic Challenge Products During Olympics Background of INTW

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Introduction The Winter Olympic Challenge Products During Olympics Background of INTW

Miller, Ryan, Executive Editor has reference to this Academic Journal, PHwiki organized this Journal Challenges of Nowcasting by George A. Isaac1, Monika Bailey1, Faisal Boudala1, Stewart Cober1, Robert Craw as long as d1, Ivan Heckman1, Laura Huang1, Paul Joe1, Jocelyn Mailhot2, Jason Milbr in addition to t2, in addition to Janti Reid1 1Cloud Physics in addition to Severe Weather Research Section, Environment Canada 2Numerical Weather Prediction Research Section, Environment Canada Workshop on Use of NWP as long as Nowcasting Boulder, Colorado, 24-26 October 2011 Introduction Results from Canadian Airport Nowcasting (CAN-Now) in addition to Science of Nowcasting Olympic Weather as long as Vancouver 2010 (SNOW-V10) Funding from Environment Canada, NAV CANADA, SAR-NIF, Transport Canada Canadian Airport Nowcasting (CAN-Now) To improve short term as long as ecasts (0-6 hour) or Nowcasts of airport severe weather. Develop a as long as ecast system which will include routinely gathered in as long as mation (radar, satellite, surface based data, pilot reports), numerical weather prediction model outputs, in addition to a limited suite of specialized sensors placed at the airport. Forecast/Nowcast products are issued with 1-15 min resolution as long as most variables. Test this system, in addition to its associated in as long as mation delivery system, within an operational airport environment (e.g. Toronto in addition to Vancouver International Airports ). Isaac et al., 2011: The Canadian Airport Nowcasting System (CAN-Now, Submitted to Meteorological Applications Isaac et al., 2011: Decision Making Regarding Aircraft De-Icing in addition to In-Flight Icing Using the Canadian Airport Nowcasting System (CAN-Now), SAE 2011 International Conference on Aircraft in addition to Engine Icing in addition to Ground Deicing, 13-17 June 2011, Chicago, Illinois, USA

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Main equipment at Pearson at the old Test in addition to Evaluation site near the existing Met compound CAN-Now Situation Chart

SNOW-V10 Science of Nowcasting Olympic Weather – Vancouver 2010 To improve our underst in addition to ing in addition to ability to as long as ecast/nowcast low cloud, in addition to visibility. To improve our underst in addition to ing in addition to ability to as long as ecast precipitation amount in addition to type. To improve as long as ecasts of wind speed, gusts in addition to direction. To develop better as long as ecast system production systems. Assess in addition to evaluate value to end users. To increase the capacity of WMO member states. Olympics Societal Benefits The Winter Olympic Challenge Steep topography, highly variable weather elements in space in addition to time 5 km Village Creekside

Canadian Models Used in SNOW-V10 Other Countries Models Used in SNOW-V10

Google Map of Outdoor Venues as long as Sochi 2014 Olympics. A box 7 km in size is drawn on map. The tops of the mountains are approximately 2200m in addition to the valley 600 m. The area is about 35 km inl in addition to from Black Sea. Products During Olympics Each group produced a Table showing 24 hour as long as ecast of significant variables as long as main venue sites (hourly intervals in addition to 10 to 15 min intervals in first two hours). Similar to what as long as ecasters produce A Research Support Desk was run during Olympics in addition to Paralympics (virtual in addition to on-site) providing real time support to as long as ecasters. A SNOW-V10 Web site was created with many of the products (time series as long as sites, remote sensing products, area displays, soundings (gondola in addition to others), in addition to a very successful Blog.

Equipment on Whistler mountain provided good data as long as as long as ecasters in addition to help in underst in addition to ing weather processes Adaptive Blending of Observations in addition to Models (ABOM) ABOM reduces to: Observation persistence when r = s = 0, w = 1 Pure observation trend when r = 0, s = 1, w = 0 Model + obs trend + persistence as long as all other r, s in addition to w Change predicted by model Forecast at lead time p Change predicted by obs trend Coefficients s in addition to r are proportional to the per as long as mance over recent history, relative to obs persistence (w) in addition to to Local tuning parameters (not yet optimized at all SNOWV10 sites) Updated using new obs data every 15 minutes Bailey ME, Isaac GA, Driedger N, Reid J. 2009. Comparison of nowcasting methods in the context of high-impact weather events as long as the Canadian Airport Nowcasting Project. International Symposium on Nowcasting in addition to Very Short Range Forecasting, Whistler, British Columbia, 30 August – 4 September 2009.

Temperature Mean Absolute Error: Averaged by Nowcast Lead Time to 6 Hours Nowcast – Model crossover lead-time Improvement over persistence Background of INTW INTW refers to integrated weighted model LAM 1k, LAM 2.5k, REG 15k in addition to RUC (CAN-Now) were selected to generate INTW Major steps of INTW generation Data pre-checking – defining the available NWP models in addition to observations Extracting the available data as long as specific variable in addition to location Calculating statistics from NWP model data, e.g. MAE, RMSE Deriving weights from model variables based on model per as long as mance Defining in addition to per as long as ming dynamic in addition to variational bias correction Generating Integrated Model as long as ecasts (INTW) Huang, L.X., G.A. Isaac in addition to G. Sheng, 2011: Integrating NWP Forecasts in addition to Observation Data to Improve Nowcasting Accuracy, Submitted to Weather in addition to Forecasting Aerials’ jump Spectator gr in addition to st in addition to Preparation of field-of-play 2 hours be as long as e training

Freestyle Skiing Ladies Aerials Final February 24, 2010 Notes by Mindy Brugman as posted on SNOW-V10 Blog The event .Last night at the Cypress aerial site it began with drizzle in addition to was quite foggy We walked to the bright lights of the venue. There was no precipitation at the venue the entire competition. The competition started at 1930 PST. The first pictures (not shown here) are taken at the start of the competition in addition to you can see that the fog was much worse at the start. I stopped taking pictures since I could not see anything. Then it began to clear just near the end of the competiton – in addition to I clicked a few pictures. You can detect a flying bug above the lights. Thats really the gold medal winner, Lydia Lassila, of Australia! Based on the event last night – I suspect ladies aerials may qualify as a new paralympic sport as long as the visually impaired. INTW Forecasts of Visibility at VOG Visibility LAM 1K including 24 hours be as long as e ladies aerials

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Ceiling LAM 2.5K including 24 hours be as long as e ladies aerials Total precip rate REG 15K including 24 hours be as long as e ladies aerials NWP Model with Minimum MAE in CAN-Now as long as Winter Dec 1/09 – Mar 31/10 in addition to Summer June 1/10 to Aug 31/10 Periods Based on First 6 Hours of Forecast

Winter period – Dec. 1, 2009 to Mar. 31, 2010 Summer period – June 1 to August 31, 2010 Winter Summer Time (h) as long as Model to Beat Persistence 6h RUC Used Huang, L.X., G.A. Isaac in addition to G. Sheng, 2011: Integrating NWP Forecasts in addition to Observation Data to Improve Nowcasting Accuracy, Submitted to Weather in addition to Forecasting Observation – Model grid match RUC temperature at CYVR July 2010 Compared data from 3 model points Consider season when selecting the best point CAN-Now: usually nearest grid point (with no water mask) J. Reid 2010

Summary RH predictions are poor, barely beating climatology. (Impacts visibility as long as ecasts) Visibility as long as ecasts are poor from statistical point of view. (also require snow in addition to rain rates) Cloud base as long as ecasts, although showing some skill, could be improved with better model resolution in boundary layer. Wind direction either poorly as long as ecast or measured. There are many difficulties in measuring parameters, especially precipitation amount in addition to type. Overall statistical scores do not show complete story. Need emphasis on high impact events. Selection of model point to best represent site is a critical process. Summary (continued) Weather changes rapidly, especially in complex terrain, in addition to it is necessary to get good measurements at time resolutions of at least 1 -15 min. CAN-Now in addition to SNOW-V10 attempted to get measurements at 1 min resolution where possible. Because of the rapidly changing nature of the weather, weather as long as ecasts also must be given at high time resolution. Verification of mesoscale as long as ecasts, in addition to nowcasts, must be done with appropriate data (time in addition to space). Data collected on hourly basis are not sufficient. Nowcast schemes which blend NWP models in addition to observations at a site, outper as long as m individual NWP models in addition to persistence after 1-2 hours. Questions

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The Respiratory System Basic functions of the respiratory system Breathing (Pulm

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The Respiratory System Basic functions of the respiratory system Breathing (Pulm

Orrange, Susan, Editorial Assistant has reference to this Academic Journal, PHwiki organized this Journal The Respiratory System Basic functions of the respiratory system Breathing (Pulmonary Ventilation) – movement of air in in addition to out of the lungs Inhalation (inspiration) draws gases into the lungs. Exhalation (expiration) as long as ces gases out of the lungs. Gas Conditioning – as gases pass through the nasal cavity in addition to paransal sinuses, inhaled air becomes turbulent. The gases in the air are warmed to body temperature humidified cleaned of particulate matter Gas Exchange – respiration Supplies body with oxygen Disposes of carbon dioxide Produces Sounds Protects respiratory surfaces Site as long as olfactory sensation Respiration Respiration – four distinct processes must happen Pulmonary ventilation – moving air into in addition to out of the lungs External respiration – gas exchange between the lungs in addition to the blood Transport – transport of oxygen in addition to carbon dioxide between the lungs in addition to tissues Internal respiration – gas exchange between systemic blood vessels in addition to tissues Functional Anatomy of the Respiratory System Respiratory organs Nose, nasal cavity, in addition to paranasal sinuses Pharynx, larynx, in addition to trachea Bronchi in addition to smaller branches Lungs in addition to alveoli

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Organs of the Respiratory System Figure 21.1 Respiratory System Consists of Respiratory muscles – diaphragm in addition to other muscles that promote ventilation Respiratory zone – site of external respiration – respiratory bronchioles, alveolar ducts, alveolar sacs, in addition to alveoli. Conducting zones Provides rigid conduits as long as air to reach the sites of gas exchange Includes nose, nasal cavity, pharynx, trachea Air passages undergo 23 orders of branching in the lungs The Nose Provides an airway as long as respiration Moistens in addition to warms air Filters inhaled air Resonating chamber as long as speech Houses olfactory receptors Skin is thin – contains many sebaceous gl in addition to s

The Nasal Cavity External nares – nostrils Divided by – nasal septum Vestibule – anterior opening Continuous with nasopharynx Two types of mucous membrane Olfactory mucosa – Near roof of nasal cavity, houses olfactory (smell) receptors Respiratory mucosa – Lines nasal cavity Epithelium is pseudostratified ciliated columnar Goblet cells within epithelium Underlying layer of lamina propria has gl in addition to s that contribute to the mucus layer in addition to blood vessels that warm the air. Cilia move contaminated mucus posteriorly Nasal Cavity Nasal Conchae 3 paired bony projections along the lateral walls of the nasal cavity Superior in addition to middle nasal conchae – part of the ethmoid bone Inferior nasal conchae – separate bone Function – Particulate matter deflected to mucus-coated surfaces

The Paranasal Sinuses Figure 7.11a, b The Pharynx Funnel-shaped passageway Connects nasal cavity in addition to mouth Shared by the digestive in addition to respiratory systems Divided into three sections by location Nasopharynx – superior portion, Oropharynx – continuous with the oral cavity Laryngopharynx – between the hyoid bone in addition to the esophagus Type of mucosal lining changes along its length The Nasopharynx Superior to the point where food enters Only an air passageway Closed off during swallowing Epithelium consists of ciliated pseudostratified epithelium that moves mucus

The Oropharynx Arch-like entranceway – fauces Extends from soft palate to the epiglottis Epithelium – stratified squamous epithelium Two types of tonsils in the oropharynx Palatine tonsils – in the lateral walls of the fauces Lingual tonsils – covers the posterior surface of the tongue The Laryngopharynx Passageway as long as both food in addition to air Epithelium – stratified squamous epithelium Continuous with the esophagus in addition to larynx The Larynx Prevent food in addition to drink from entering the trachea Passageway as long as air Produces Sound It connects the pharynx to the trachea Epithelium of the larynx Stratified squamous – superior portion Pseudostratified ciliated columnar – inferior portion

Nine Cartilages of the Larynx Thyroid cartilage – shield-shaped, as long as ms laryngeal prominence (Adam’s apple) Three pairs of small cartilages Arytenoid cartilages Corniculate cartilages Cunei as long as m cartilages Epiglottis – tips inferiorly during swallowing The Larynx Vocal ligaments of the larynx Vocal folds (true vocal cords) – act in sound production Vestibular folds (false vocal cords) – no role in sound production Voice production Length of the vocal folds changes with pitch Loudness depends on the as long as ce of air across the vocal folds The Trachea Descends into the mediastinum C-shaped cartilage rings keep airway open Carina – marks where trachea divides into two primary bronchi Epithelium – pseudostratified ciliated columnar

The Trachea Figure 21.7a, b Bronchi in the Conducting Zone Bronchial tree – extensively branching respiratory passageways Primary bronchi (main bronchi) Largest bronchi Right main bronchi – wider in addition to shorter than the left Secondary (lobar) bronchi Three on the right Two on the left Tertiary (segmental) bronchi – branch into each lung segment Bronchioles – little bronchi, less than 1 mm in diameter Terminal bronchioles – less than 0.5 mm in diameter Tissue Composition of Conducting Zone Changes along pathway Supportive connective tissues change C-shaped rings – trachea, primary bronchi Replaced by cartilage plates, secondary & tertiary bronchi Epithelium changes First, pseudostratified ciliated columnar – trachea Replaced by simple columnar – bronchi Then simple cuboidal epithelium – bronchioles in addition to terminal bronchioles Smooth muscle becomes important at the bronchioles – controlled by the ANS (bronchoconstriction in addition to bronchodilation).

Lobes in addition to Surfaces of the lungs Right lung has three lobes Left lung has two lobes Concavity on medial surface = cardiac notch Bronchi enter the lungs at the hilus The Pleurae A double-layered sac surrounding each lung Parietal pleura Visceral pleura Pleural cavity – potential space between the visceral in addition to parietal pleurae Pleurae help divide the thoracic cavity Central mediastinum Two lateral pleural compartments Structures of the Respiratory Zone Consists of air-exchanging structures Respiratory bronchioles – branch from terminal bronchioles Lead to alveolar ducts Lead to alveolar sacs

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Structures of the Respiratory Zone Figure 21.9b Features Of Alveoli Alveoli cell types Type I cells site of gas exchange in addition to Type II cells – secrete surfactant Macrophages Surrounded by basal laminae in addition to elastic fibers Interconnect by way of alveolar pores Internal surfaces – site as long as free movement of alveolar macrophages Figure 21.10b

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Introduction so that US Taxation of Mergers in addition to Acquisitions Pro

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CollegeAmerica-Colorado Springs South, CO has reference to this Academic Journal, Introduction so that US Taxation of Mergers in addition to Acquisitions Prof. Charlotte Crane Graduate Tax Program Northwestern University School of Law Chicago, Illinois Basic Principles of Taxation of US Corporations Two levels of tax Corporation pays tax on earnings as earned Shareholders pay tax when earnings distributed Worldwide income of US corporation taxed by US Mitigated by foreign tax credit Tax law not always linked so that state corporate law Double taxation of Corporate Earnings Domestic Corporation honored as separate taxable entity Corporation taxed at 35% $1000 -350= 650 Pre-2004 Individual shareholders taxed at 30-35% on receipt of dividend Pre-2004 650-195=455 Post-2004 individual shareholders taxed at 15% Post-2004 650-97.50=552.50 No shareholder credit in consideration of corporate taxes paid No corporate deduction in consideration of dividend paid No rate difference between income distributed in addition to income not distributed Except when penalty taxes in consideration of accumulations

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US corporate tax rates 2004 stated rates Up so that $50,000 15% Over 50,000 but not over $75,000 25% Over 75,000 but not over $10,000,000 34% Over $10,000,000 35% 2004 rates including phaseout of lower brackets Up so that $50,000 15% Over 50,000 but not over $75,000 25% Over 75,000 but not over $100,000 34% Over 100,000 but not over $10,000,000 39% Over $10,000,000 but not over $15,000,000 35% Over $15,000,000 but not over 18,333,333 38% Over $18,333,333 35% But only double taxation Dividends received deduction With control 100% in consideration of 80% or greater ownership Without control 80% in consideration of 20-80% ownership 70% in consideration of under 20% But more than double tax not always avoided And not always of single entity Election of affiliated group so that file consolidated returns Only US corps may consolidate And contiguous in some cases Only ownership not operation requirements in consideration of eligibility Disregarded entities (also called Tax Nothings) Partnerships in addition to LLCs when owned by one shareholder will be treated as if they did not exist in consideration of tax purposes when box is checked so that treat as pass-through entity Corp Corp

Meaning of control 1504 vote in addition to value 368(c) all voting in addition to stock by class Subpart F 50% owned by 10% shs All can be subject so that their own attribution in addition to look-through rules Disregarded status extends so that foreign entities Regulations specify certain per se entities Others may be pass-through Some tension in possibility of market in foreign entities Tax law not corporate law controls tax treatments Corporate law determined primarily by states Corporate charters controlling governance in addition to relations alongside shareholders Relations alongside creditors Procedures in consideration of in addition to results of restructuring in consideration of non-tax purposes Federal law governs access so that public capital markets Securities offerings (except very small scale) Fraud on shareholders (shares alongside states) Federal tax law not tied so that state charter or governance law ?corporation?, ?dividend,? ?earnings in addition to profits,? ?stock,? ?debt? State law may be necessary in consideration of federal tax treatment, but not determinative-?merger? as one route so that tax-free restructuring State law may be easiest but not only way-?complete liquidation?

Introduction so that US Taxation of Mergers in addition to Acquisitions Pro

Sources of US income tax law Internal Revenue Code enacted by Congress Regulations promulgated by Treasury Department, written alongside Internal Revenue Service Published rulings by IRS Unpublished rulings by IRS Private letter rulings Field Service advice, Technical advice memoranda (designations have changed) Court interpretations?only alongside litigation over actual deficiency Treaties What will be taxed as corporation? Historically very difficult problem so that administer Sometimes taxation as corporation preferred, sometimes not Previously, if entity provided limited liability so that owners, must be taxed as corporation Lawyers found ways so that offer effective limited liability ?Check the box? now allows any entity that does not have a Charter as a corporation under state law Market made in its interests Not available so that those corporations that are taxed as bank or insurance coompanies, or certain foreign entities Election so that be taxed as partnership?called ?pass- through? Cannot change election more often than every 60 months If ?passthrough? single owner, will be disregarded Foreign entities that will be taxed as corporations Austria, Aktiengesellschaft Belgium, Societe Anonyme France, Societe Anonyme Germany, Aktiengesellschaft Italy, Societa per Azioni Japan, Kabushiki Kaisha Mexico, Sociedad Anonima Netherlands, Naamloze Vennootschap United Kingdom, Public Limited Company

Earnings: based on taxable income of corporations No general conformity between book income in addition to tax income Schedule M required, but not always useful Schedule M may be revised so that require more useful information Book (financial) income rarely has impact on tax income Cost recovery used as incentive Costs of many self-developed intangibles deductible Costs of purchased intangibles amortizable since 1993 Original issue discount Double Tax only applies so that earnings With debt of 60% at 10% 1000 gross corporate earnings 60 interest 940 net taxable income 329 tax on net 611 earnings so that shareholders 91.65 tax by sh 519.35 after tax so that shareholders 39 after tax so that creditors 558.35 combined after tax Creates enormous pressure in consideration of debt financing Without debt 552 after tax so that shareholders Computation of Earnings in addition to Profits

Distinguishing debt from equity Section 385(b) five factors (1) whether there is a written unconditional promise so that pay, on demand or on a specified date, a fixed amount in money in return in consideration of an adequate consideration in addition to so that pay a fixed rate of interest; (2) whether there is a subordination to, or a preference over, other debt; (3) the ratio of debt so that equity; (4) whether there is convertibility of debt into stock; in addition to (5) the relationship between stockholdings in addition to holdings of the interest in question Other factors: Whether regular creditor?s remedies are available Extent so that which participate in corporation gains OR losses Participation in governance (rarely determinative) Distinguishing debt from equity other approaches No fixed standards limiting shareholder debt No single statutory or regulatory standard Especially difficult when related parties Concern about excess debt in consideration of non-tax reasons (?) Other limits?deny debt feature Section 269 denial of deduction in consideration of acquisition indebtedness when debt in addition to equity stapled Section 163(j) denial of deduction ?excess interest? so that extent more than 50% of income (using special definition of income, closer so that cash flow) Paid so that related party (50% common ownership) Debt so that equity ratio 1.5 so that 1 or less Can include third party debt guaranteed by related party Section 263(l) ?payment in kind Other sections may deny equity features of securities denominated ?stock? Debt /Equity Ratio In some places statutorily defined, but in others not Frequently tax basis of assets (not book or fmv) used in consideration of tax purposes Liabilities/Total basis-liabilities Not likely so that produce same result as bankers or other analysts would use Evidence of problems in structuring Code in which same rules apply so that small closely held as so that large publicly-held?common law nature of evolution of US code

Assets of Target Corporation Domestic property transactions: Capital Gains Nature of assets involved Most stock, financial instruments Not inventory, depreciable property Land All taxable unless taxpayer not taxable tax-exempt charity pension plan government unless specific transaction not taxable tax-free exchanges of certain types of property Tax-free corporate restructuring unless held by individual at death?stepped up basis so that fmv Domestic property transactions: Capital Gains Rate in addition to limitations Individuals taxed at favorable rate?15% Includes most individual holding of corporate stock Except by dealers Except in personal retirement accounts Dividends now at 15% also No special corporate rate in consideration of capital gains Limitations on losses in consideration of both individuals in addition to corporations

Domestic property transactions: depreciable property Nature of assets involved Machinery in addition to equipment Improved real estate Special treatment Prior deductions may be ?recaptured??1245 in addition to 1250 Recapture income may be triggered when other income not Extent of Double Tax Regime Alternative regimes Passthrough of current income, corporate level asset gain Subchapter S Full pass-through; no entity level tax Partnership Limited Liability Company Full-passthrough entities may ?check the box? If single owner, become ?disregarded entities? Not eligible if market made in interests Distributions so that Shareholders Included in income of shareholders so that extent of earnings [ignore intricate rules making current e&p available if past losses] No basis offset in consideration of receipt of dividend Shareholder can have dividend even if holds stock at a loss Shareholder can have dividend even if just purchased stock No change in shareholder basis as result of income earned No shareholder credit in consideration of corporate level taxes paid Proposal last year was modified version of this, giving shareholder exemption in consideration of fully taxed corporate income Only if NO earnings in addition to profits will shareholders have return of capital Return of capital distributions NOT income in consideration of US tax purposes?no withholding

Example of treatment of individual shareholder Purchased in consideration of $1000 Now worth $800 Shareholder receives dividend of $65 from earnings in addition to profits (100 of corporate income) 65 of dividend is taxable at 15% Leaving shareholder alongside $55.25 of $100 corporate earnings If stock decline in value in connection alongside dividend so that 760 shareholder basis in stock still 1000 shareholder recognizes loss of 240 only on sale of stock Dividend treatment avoided if sale possible Individual preference in consideration of cashing in stock gains Before rate reduction, individual shareholders sought so that avoid dividends?all taxed, highest rate Very low dividend payouts by many US corporations With rate reduction, less concerned unless very high basis Large enough change so that effect corporate behavior?? Rate reduction set so that expire in 2009 Distributions so that Corporate Shareholders Dividends received deduction available in consideration of corporations section 243 Varies alongside level of ownership 100% if 80% or more 80% if 20-80% 70% if less than 20%

Corporate preference in consideration of cashing in stock gains Corporate shareholders may prefer dividends so that sale or exchange Corporate shareholder may pay itself dividend from subsidiary before selling Non-liquidating distributions of property so that shareholders generally taxable Treated as dividend received by shareholders Triggers gain so that distributing corporations No losses triggered Losses triggered only on sale No losses on sale so that related party Even so that unrelated party, sale not honored if buyer not take economic risk Even of subsidiary stock unless qualifies as spin-off under reorganization rules Share Repurchases Redemptions Share repurchases in US are legal so long as shareholders not preferred over others inappropriately ?Greenmail? Designation of transaction as sale so that issuing corporation will not control

Non-tax considerations in choice of nontaxable or nontaxable Financial accounting in consideration of the acquired stock in addition to assets ?Pool accounting? no longer available FASB 141 Non-merger alternatives Using dividend in addition to liquidation equalization agreements Dual headed structures have been used alongside holding company or ?synthetic?with equalization agreement: Royal Dutch/Shell Transport Reed/Elsevier To avoid adverse affect in public markets Aversion so that foreign stock De-indexation affects To avoid taxable exchange of shares To avoid post-merger withholding taxes Not tried in US?perception of base erosion problems

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This Particular Journal got reviewed and rated by Example of treatment of individual shareholder Purchased in consideration of $1000 Now worth $800 Shareholder receives dividend of $65 from earnings in addition to profits (100 of corporate income) 65 of dividend is taxable at 15% Leaving shareholder alongside $55.25 of $100 corporate earnings If stock decline in value in connection alongside dividend so that 760 shareholder basis in stock still 1000 shareholder recognizes loss of 240 only on sale of stock Dividend treatment avoided if sale possible Individual preference in consideration of cashing in stock gains Before rate reduction, individual shareholders sought so that avoid dividends?all taxed, highest rate Very low dividend payouts by many US corporations With rate reduction, less concerned unless very high basis Large enough change so that effect corporate behavior?? Rate reduction set so that expire in 2009 Distributions so that Corporate Shareholders Dividends received deduction available in consideration of corporations section 243 Varies alongside level of ownership 100% if 80% or more 80% if 20-80% 70% if less than 20% and short form of this particular Institution is CO and gave this Journal an Excellent Rating.