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Monday, September 12, 2016

Bottom of a Well: Cook and Bezos punch (slightly) about Our weight

There are times when we must sink to the bottom of our misery to understand truth, just as we must descend to the bottom of a well to see the stars in broad daylight.
~ Vaclav Havel

Memory and attention are affected by much lower levels of dehydration than previously thought The Conversation 


The 9/11 attack on the United States has a number of villains rightfully attached to its history. But there are also a number of heroes who emerged on that day as well. Some ran into the carnage to save lives, giving theirs in the process... 



Scott Adams: “If humans were rational creatures, the time and place of Clinton’s ‘overheating’ wouldn’t matter at all. But when it comes to American psychology, there is no more powerful symbol of terrorism and fear than 9-11 . When a would-be Commander-in-Chief withers – literally – in front of our most emotional reminder of an attack on the homeland, we feel unsafe. And safety is our first priority.”

Auden gradually renounced the public stage for a private, meditative life. "When the ship catches fire," he advised, " sit still and pray  " 

… Mother Teresa is ‘Saint of the Doubters,’ says Jesuit author | Deseret News. 

We know from the publication of her diaries and her letters that she suffered this “dark night” for the last half of her life. None of the saints had to do the kinds of things she did on an empty tank. So for me that makes her the greatest modern saint. The great irony is that this most traditional of saints becomes the patron for people who doubt, people who seek, people who are agnostic. She becomes the “Saint of the Doubters,” which no one would have suspected during her lifetime.


Jack Townsend, Court Denies Petition to Quash IRS Summons Issued Pursuant to Russian Request Under Double Tax Treaty. It seems unwise to use our law enforcement apparatus to help the notoriously political Russian tax authorities

Room for Real Time Improvement by ACORN: ATO Warns of phone scam requesting payment for tax debts

Strong Unions Help All Workers—Not Just Union Workers In These Times

[Jack Townsend]  read an interesting newsy article on tax crimes that readers might find interesting:  Brian Lisi, The biggest tax evaders in US history on the anniversary of Leona Helmsley's 1989 conviction  Biggest tax evaders anniversary conviction.  The article discusses Helmsley and other prominent persons convicted of tax evasion or having large tax debts... More Jack Townsend taxcrimes.blogspot 

SIGNS AND PORTENTS:   A Russian River Mysteriously Turned Blood Red. And no one’s saying why

Certain stories that get virtually no traction nevertheless involve phenomena that are quite important in understanding the way the world operates.  One instance is the network of secrecy jurisdictions (“tax havens”), which play a huge role in the global economy by providing back channels used by a substantial fraction of the world’s wealth.  For those interested in the details, one good place to start is Nicholas Shaxson’s 2010 book Treasure Islands.... Czech out this story as the Bahamas decides to compete aggressively to become the most infamous tax haven around The Bahamas giant fist pumping screw you to the civilized world

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One and only Steve Jobs:

Apple’s Move To Tighten Digital Health Criteria Could Have Bigger Impact Than FDA MedCity News

he OPM Data Breach: How the Government Jeopardized Our National Security for More than a Generation House Committee on Oversight and Government Reform

The only Harry Potter analogy to tax proposals you’ll ever need. [TaxProf Blog]

How Bezo's Amazon and the CIA Want to Teach AI to Watch Us from Space MIT Technology Review

How Facebook can affect your credit score Financial Times




Facebook recommended that this psychiatrist’s patients friend each other Fusion


Facebook Purges Journalists, Immediately Promotes a Fake Story for 8 Hours

"Selfies in voting booths: Depending on where you live, they may be illegal; A New Hampshire law says selfie ban is needed to curtail vote buying and coercion." David Kravets of Ars Technica has this report

Imagine a government chosen by those with knowledge of politics, economics, and policy. No more rule by the dismayingly ignorant. The appeal is clear - and fatal  Democracy ...

The UK government is still in denial on the tax gap

Fabio Ambrosio (Pacific Lutheran University), New Heightened Reporting Requirements for Foreign Financial Activities: What Every Fiduciary Should Know About a Decedent’s Unfulfilled Compliance Obligations, 6 Tax Dev. J. 1 (2016)

The Critical Question. Is Tax Cheating Going to Increase? (Jim Maule) “Yes.”



CloudOrly Mazur (SMU), Transfer Pricing Challenges in the Cloud, 57 B.C. L. Rev. 643 (2016):

Cloud computing — the provision of information technology resources in a virtual environment — has fundamentally changed how companies operate. Companies have quickly adapted by moving their businesses to the cloud, but international tax standards have failed to follow suit. As a result, taxpayers and tax administrations confront significant tax challenges in applying outdated tax principles to this new environment. One particular area that raises perplexing tax issues is the transfer pricing rules. The transfer pricing rules set forth the intercompany price a cloud service provider must charge an affiliate using its cloud services, which ultimately affects in which jurisdiction the company’s profits are taxed. This Article argues that the fundamental features of cloud computing exacerbate some of the more difficult transfer pricing problems that already exist.


Florida Tax Review  (2015)Walter Hellerstein (Georgia), A Hitchhiker’s Guide to the OECD’s International VAT/GST Guidelines, 18 Fla. Tax Rev. 589 (2016):

The OECD’s International VAT/GST Guidelines, which were released in their consolidated form at the OECD’s Global Forum on VAT in Paris in late 2015, are the culmination of nearly two decades of efforts to provide internationally accepted standards for consumption taxation of cross-border trade, particularly trade in services and intangibles. This article provides a roadmap to the Guidelines, especially for readers who may be unfamiliar with consumption tax principles, in general, or VATs in particular.


Euphemisms are like underwear: best changed frequently. What a warm, charitable word welfare is at its core, and how much static and bile we must peel away to hear it that way again


Hossein Amini, who wrote the screenplays for The Wings of the Dove, and Drive: “The biggest advantage of adapting an impossible book is that no one expects you to be entirely slavish to the source material. They’re not expecting a filmic replica. … I flatter myself when I say they felt halfway between adaptations and original screenplays, but that’s really a testament to the greatness of the novels. They not only allow you to see something of yourself in them, they allow you to project.”  The bigger they come: how to film an 'unfilmable' book

European Commission Press Release: “The European Commission has concluded that Ireland granted undue tax benefits of up to €13 billion to Apple. This is illegal under EU state aid rules, because it allowed Apple to pay substantially less tax than other businesses. Ireland must now recover the illegal aid. Commissioner Margrethe Vestager, in charge of competition policy, said:“Member States cannot give tax benefits to selected companies – this is illegal under EU state aid rules. The Commission’s investigation concluded that Ireland granted illegal tax benefits to Apple, which enabled it to pay substantially less tax than other businesses over many years. In fact, this selective treatment allowed Apple to pay an effective corporate tax rate of 1 per cent on its European profits in 2003 down to 0.005 per cent in 2014.” Following an in-depth state aid investigation launched in June 2014, the European Commission has concluded that two tax rulings issued by Ireland to Apple have substantially and artificially lowered the tax paid by Apple in Ireland since 1991. The rulings endorsed a way to establish the taxable profits for two Irish incorporated companies of the Apple group (Apple Sales International and Apple Operations Europe), which did not correspond to economic reality: almost all sales profits recorded by the two companies were internally attributed to a “head office”
Official Google Blog – Search is a Jack of all trades – August 25, 2016 – “Today we’re dealing two new hands from the Google Search deck: solitaire and tic-tac-toe. Now you can play two of the oldest and most popular games for all ages, on desktop and in the Google app. It’s been said solitaire’s roots are in fortune telling. If that’s true, today your fate rests on your quick wit and the luck of the draw. When you search for “solitaire” on Google, the familiar patience game may test yours!”



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Lawyers love Twitter, and when a chance to put aside their work and flex their creative muscles arises, they quickly pounce on the opportunity. Earlier this week, lawyers and law students got together and dreamed up bands that only lawyers could love, and boy, did this nerd party trend quickly.

Behold, the #AppellateBandNames,#AppellateBandName, and #AppellateBands hashtags. We’ve selected a few that we thought were the funniest. Feel free to join in the fun with your own on Twitter.


Via Mendeley Blog: “Elsevier takes the next step in making researchers’ lives easier with the new DataSearch engine.  You can search for research data across numerous domains and various types, from a host of domain-specific and cross-domain data repositories. It’s available at https://datasearch.elsevier.com/


The king said, “What punishment should someone receive who drags an innocent victim out of bed and throws her into the river to drown?”
The stepmother said at once, “That’s a dreadful crime. The murderer should be put in a barrel studded with nails, and rolled downhill into the water.”
“Then that is what we shall do,” said the king.
He ordered such a barrel made, and as soon as it was ready, the woman and her daughter were put inside and the top was nailed down. The barrel was rolled downhill till it fell into the river, and that was the end of them. How Shaun Tan transformed children’s literature

Puig, Sergio, Tobacco Litigation in International Courts (August 24, 2016). 57 Harvard International Law Journal, Forthcoming; Arizona Legal Studies Discussion Paper No. 16-30. Available for download at SSRN:http://ssrn.com/abstract=2829196 “For years, tobacco interests have played an important role in developing international law. Recently, cooperation among nations concerned with the risks and health consequences of smoking tobacco has resulted in the adoption of international treaties, regional directives, and common administrative and regulatory practices

 
Take anger. From Newton’s obsessive grudges to Beethoven’s tantrums – which sometimes came to blows – it seems as though visionary geniuses often come with extremely short tempers. There are plenty of examples to be found in Silicon Valley. Amazon founder Jeff Bezos is famed for his angryoutbursts and insults (such as “I’m sorry, did I take my stupid pills today?”) yet they haven’t stopped him building a $300 billion company. Why it pays to be grumpy and bad tempered


This tree in Greece is Europe’s oldest known living tree Christian Science Monitor

 "The inmost spirit of poetry, in other words, is at bottom, in every recorded case, the voice of pain — and the physical body, so to speak, of poetry, is the treatment by which the poet tries to reconcile that pain with the world."

~ Ted Hughes

How Much Trash in Near Your Home?: “The average American tosses 4.4 pounds of trash every single day. It may not seem all that astonishing on the surface, but with 323.7 million people living in the United States, that is roughly 728,000 tons of daily garbage – enough to fill 63,000 garbage trucks. That is 22 billion plastic bottles every year. Enough office paper to construct a 12-foot-high wall from Los Angeles to Manhattan. It is 300 laps around the equator in paper and plastic cups, forks, and spoons. It is 500 disposable cups per average American worker – cups that will still be sitting in the landfill five centuries from now. Approximately half of the 254 million tons of yearly waste will meet its fate in one of the more than 2,000 active landfills across the country – and you probably live, work or socialize closer to one than you may think…”


BYU Marriott School News – “Software developers listen up: if you want people to pay attention to your security warnings on their computers or mobile devices, you need to make them pop up at better times. A new study from BYU, in collaboration with Google Chrome engineers, finds the status quo of warning messages appearing haphazardly—while people are typing, watching a video, uploading files, etc.—results in up to 90 percent of users disregarding them. Researchers found these times are less effective because of “dual task interference,” a neural limitation where even simple tasks can’t be simultaneously performed without significant performance loss. Or, in human terms, multitasking. “We found that the brain can’t handle multitasking very well,” [emphasis added] said study coauthor and BYU information systems professor Anthony Vance. ... “But you can mitigate this problem simply by finessing the timing of the warnings,” said Jeff Jenkins, lead author of the study appearing in Information Systems Research, one of the premier journals of business research. “Waiting to display a warning to when people are not busy doing something else increases their security behavior substantially.”


An escalating battle between Apple Inc. and Spotify Ltd. is leaving some musicians caught in the crossfire Spotify Is Burying Musicians for Their Apple Deals