Search results

This paper aims to explain how the Bipartisan Budget Act of 2015, as modified by the Protecting Americans from Tax Hikes Act of 2015, changes the way the US Internal Revenue Service will conduct audits of collective investment vehicles treated as partnerships for US tax purposes.

This study explains the entities covered by the new partnership audit regime, the effective dates of the new regime and steps to be taken by funds covered by the new audit regime.

The results show that the new regime creates a liability at the partnership level for any unpaid tax, placing the tax burden on current-year partners.

A fund manager should determine whether the new audit regime is applicable to any of the funds he or she is managing and, if so, amend the fund documents to accommodate the new audit rules, providing a mechanism to elect and supervise a partnership representative, a mechanism to allocate the economic burden of the tax to the appropriate partners and a procedure for selecting the method to calculate the amount of the fund’s tax liability attributable to an audit.

This study provides practical guidance from experienced investment, fund and tax lawyers.

To explain the final position limit aggregation rules and exemptions pertaining to derivative positions in nine agricultural commodities adopted by the Commodity Futures Trading Commission on December 5, 2016 and effective February 14, 2017, the notice filing deadline with respect to which was extended by the CFTC by limited time no-action relief until August 14, 2017.

Explains the position limit aggregation rules and exemptions pertaining to equity interests in owned entities, ownership or equity interests in pooled accounts or positions, positions of an “eligible entity” in connection with client positions carried by an “independent account controller,” positions held by futures commission merchants (FCMs) in discretionary accounts or customer trading program accounts, equity interests of underwriters based on unsold allotments of securities in distributions, broker-dealers if the equity interest is acquired in the normal course of business and positions for which information cannot be collected without risk of violating a law.

Unless an exemption from aggregation is available, all positions in accounts for which any person controls the trading or holds a 10 per cent or greater ownership or equity interest must be aggregated with positions held, and trading done, by such person. The final rule adds several new exemptions, including for persons with a 10 per cent or greater ownership or equity interest in an entity so long as certain conditions establishing independence are met. The final rule requires notice filing to take advantage of most exemptions from aggregation.

Practical guidance from experienced lawyers specializing in securities, funds, and investment management.

While building robots with anything akin to human cognition and intelligence remains a far off vision, making them more autonomous and responsive will allow them to be used in a greater variety of sophisticated tasks in the manufacturing and service sectors. With this aim, various groups of European researchers are making important progress on developing the technologies and bringing them together in a new generation of machines that are more aware of their environment and better able to interact with humans. This paper aims to look at this issue.

This paper looks at how various groups of European researchers are making progress in developing a new generation of machines that are more aware of their environment and better able to interact with humans.

The paper finds that replicating human‐like intelligence and awareness is still a long way of – if indeed possible but researchers foresee robots akin to those they have developed becoming an everyday sight over the coming years in what are described as “gofer scenarios”

The paper provides useful information on developments in robtics.

Finite element solutions of improved quality are obtained by optimizing the location of nodes of the finite element grid, while keeping the number of degrees of freedom fixed. The formulation of the grid optimization problem is based on the reduction of error associated with interpolation of the exact solution, using functions from the finite element space. Element sizes are selected as design variables: length in R and area in R. Approximate optimal conditions are introduced to obtain a set of operationally useful equations that can be used as guidelines for construction of improved grids. Example problems are given for illustrations.

To examine a statement issued by Justice Antonin Scalia on November 10, 2014, concurrently with the Supreme Court ' s denial of certiorari in a criminal insider trading case, which raises profound questions about how the courts interpret the federal securities laws and the degree of deference they give to the Securities and Exchange Commission (SEC) in the context of criminal enforcement.

The article discusses the points raised in the justice ' s statement and their potential implications for future securities enforcement cases.

The statement suggests that the traditional deference courts accord the SEC under the landmark decision in Chevron USA Inc. v. Natural Resources Defense Council, Inc., 467 US 837 (1984) may be inappropriate and potentially inconsistent with the rule of lenity, which requires that ambiguous criminal laws be interpreted in a defendant ' s favor.

Expert guidance from experienced securities lawyers.

To evaluate critically whether under a market system, monetary exchange is always and everywhere based on profit‐seeking behaviour, this article examines cash‐in‐hand work, a form of activity conventionally conceptualised as low paid employment heavily imbued with profit motivations on the part of both the consumer and supplier. Reporting data gathered through structured face‐to‐face interviews with 511 households in affluent and deprived neighbourhoods in two English cities, this article reveals that although most cash‐in‐hand work conducted by people living in affluent suburbs is conducted under social relations akin to employment for profit‐motivated purposes, the vast majority of cash‐in‐hand work in deprived neighbourhoods is undertaken by and for kin, neighbours and friends for a range of cooperative reasons under social relations more akin to unpaid community exchange. Given this heterogeneity of cash‐in‐hand work, this article questions whether seeking its eradication through more stringent regulations is the appropriate policy response, especially in deprived neighbourhoods.

To examine the proposed rules issued by the Securities and Exchange Commission (SEC) pursuant to Section 954 of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010, which, if adopted, would require national stock exchanges to establish listing standards that would require listed issuers to adopt so-called clawback policies for the recovery of excess incentive-based compensation in the event that an issuer is required to prepare an accounting restatement resulting from material noncompliance with any financial reporting requirement.

The article discusses the SEC’s proposed rules, including the circumstances that would require recovery of excess incentive-based compensation, the types of compensation that, and the individuals whose compensation, would be subject to recovery, and certain new disclosure requirements for listed issuers.

The SEC’s proposed rules will, if adopted, impose additional burdens on listed issuers to adopt and comply with recovery policies for excess incentive-based compensation and adhere to new public disclosure requirements.

Expert analysis from experienced securities and executive compensation lawyers.

This paper aims to explore the implications of integrating humanoid service robots into hospitality service encounters by evaluating two service prototypes using Softbank Robotics’ popular service robot Pepper™: to provide information (akin to a receptionist) and to facilitate order-taking (akin to a server). Drawing both studies together, the paper puts forward novel, theory-informed yet context-rooted design principles for humanoid robot adoption in hospitality service encounters.

Adopting a multiple method qualitative approach, two service prototypes are evaluated with hospitality and tourism experts (N = 30, Prototype 1) and frontline hospitality employees (N = 18, Prototype 2) using participant observation, in situ feedback, semi-structured interviews and photo-elicitation.

The adoption of humanoid service robots in hospitality is influenced by the following four layers of determinants: contextual, social, interactional and psychological factors, as well as extrinsic and intrinsic drivers of adoption. These empirical findings both confirm and extend previous conceptualizations of human-robot interaction (HRI) in hospitality service.

Despite using photo-elicitation to evoke insight regarding the use of different types of service robots in hospitality, the paper mostly focuses on anthropomorphized service robots such as Pepper™.

Adopting humanoid service robots will transform hospitality operations, whereby the most routine, unpleasant tasks such as taking repeat orders or dealing with complaints may be delegated to service robots or human-robot teams.

Working with and receiving service from Pepper™ changes the service encounter from direct practical, technical considerations to more nuanced social and psychological implications, particularly around feelings of self-esteem, social pressure and social judgment.

This paper presents one of the first empirical studies on HRI in hospitality service encounters using Softbank Robotics’ Pepper™. In doing so, the paper presents a novel framework for service robot adoption rooted in first-hand user interaction as opposed to previous, theory-driven conceptualizations of behavior or empirical studies exploring behavioral intention.

A procedure presented for displaying variables in colour on an isoparametric surface. It utilizes isoparametric interpolation functions to produce continuous colour variations on the surface. It can also be employed on standard printers for non‐colour displays.