The IRS University Compliance Project Report on UBIT Issues: Roadmap for Enforcement...Reform...or Repeal?
In: National Center on Philanthropy and the Law, New York, NY, October 2013
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In: National Center on Philanthropy and the Law, New York, NY, October 2013
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Working paper
In: Illinois Public Law Research Paper No. 13-46
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Working paper
In: Annual Conference of the National Center on Philanthropy and the Law, New York, NY, 2009
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Working paper
In: Social development, Band 25, Heft 4, S. 687-703
ISSN: 1467-9507
AbstractThe term social attention has become widely used during the last decade, appearing within behavioral neuroscience and developmental neurocognitive literatures to characterize a variety of activities and cognitive processes that emerge in the presence of conspecifics. We provide here an overview of the current status of social attention as a construct, as reflected in its appearance in research studies, and we offer a framework for characterizing the extant literature based on the functions of social attention processes: as behavior for social communication, as motivation to engage in social communication, and as a form of basic visual attention in the context of other social agents. We then provide two overarching questions to guide future research efforts directed toward establishing the utility of social attention as an independent and/or unified construct. We then consider implications and recommendations for future research efforts.
This Article examines the growing controversy over the multi-billion dollar charitable tax exemption enjoyed by nonprofit hospitals. It begins by articulating four criteria for evaluating a rationale of the charitable exemption: deservedness, incorporating the elements of worth and need; proportionality; universality; and historical consistency. The Article then employs these criteria to refute three conventional explanations of why nonprofit hospitals are exempt: because health care is a per se charitable activity; because the treatment of indigent patients relieves a government burden; and because nonprofit hospitals provide community benefits. The Article also uses these criteria to refute two academic theories: Boris Bittker's income measurement rationale and Henry Hansmann's capital subsidy theory. This Article proposes a "donative theory" as an alternative rationale for the charitable exemption. The donative theory posits that "charity" describes an entity capable of attracting a substantial level of philanthropic support from the public at large. Donations exist where there is a combined failure of private markets and direct public funding to supply a shared public benefit at the optimally desired level. Donative institutions deserve a tax subsidy because the public's support signals their worth, and the free-rider tendency that affects all giving assures the need for an additional, shadow subsidy. The Article further demonstrates that the donative theory comports with the statutory scheme and the four centuries of legal history that shape the legal concept of charity. In particular, the donative theory provides the only explanation of the tax law's otherwise unjustifiable reliance on the law of charitable trusts.
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In: Developmental science, Band 20, Heft 5
ISSN: 1467-7687
AbstractLong‐chain polyunsaturated fatty acids (LCPUFA) have been shown to be necessary for early retinal and brain development, but long‐term cognitive benefits of LCPUFA in infancy have not been definitively established. The present study sought to determine whether LCPUFA supplementation during the first year of life would result in group differences in behavior and event‐related potentials (ERPs) while performing a task requiring response inhibition (Go/No‐Go) at 5.5 years of age. As newborns, 69 children were randomly assigned to infant formulas containing either no LCPUFA (control) or formula with 0.64% of total fatty acids as arachidonic acid (ARA; 20:4n6) and various concentrations of docosahexaenoic acid (DHA; 22:6n3) (0.32%, 0.64% or 0.96%) for the first 12 months of life. At 5.5 years of age, a task designed to test the ability to inhibit a prepotent response (Go/No‐Go) was administered, yielding both event‐related potentials (ERPs) and behavioral data. Behavioral measures did not differ between groups, although reaction times of supplemented children were marginally faster. Unsupplemented children had lower P2 amplitude than supplemented children to both Go and No‐Go conditions. N2 amplitude was significantly higher on No‐Go trials than Go trials, but only for supplemented children, resulting in a significant Group × Condition interaction. Topographical analysis of the ERPs revealed that the LCPUFA‐supplemented group developed a novel period of synchronous activation (microstate) involving wider anterior brain activation around 200 ms; this microstate was not present in controls. These findings suggest that LCPUFA supplementation during the first 12 months of life exerts a developmental programming effect that is manifest in brain electrophysiology. A video abstract of this article can be viewed at: https://www.youtube.com/watch?v=oM2leg4sevs.
In: Koletzko , B , Bergmann , K , Brenna , J T , Calder , P C , Campoy , C , Clandinin , M T , Colombo , J , Daly , M , Decsi , T , Demmelmair , H , Domellöf , M , FidlerMis , N , Gonzalez-Casanova , I , van Goudoever , J B , Hadjipanayis , A , Hernell , O , Lapillonne , A , Mader , S , Martin , C R , Matthäus , V , Ramakrishan , U , Smuts , C M , Strain , S J J , Tanjung , C , Tounian , P & Carlson , S E 2020 , ' Should formula for infants provide arachidonic acid along with DHA? A position paper of the European Academy of Paediatrics and the Child Health Foundation ' , The American journal of clinical nutrition , vol. 111 , no. 1 , pp. 10-16 . https://doi.org/10.1093/ajcn/nqz252
Recently adopted regulatory standards on infant and follow-on formula for the European Union stipulate that from February 2020 onwards, all such products marketed in the European Union must contain 20-50 mg omega-3 DHA (22:6n-3) per 100 kcal, which is equivalent to about 0.5-1% of fatty acids (FAs) and thus higher than typically found in human milk and current infant formula products, without the need to also include ω-6 arachidonic acid (AA; 20:4n-6). This novel concept of infant formula composition has given rise to concern and controversy because there is no accountable evidence on its suitability and safety in healthy infants. Therefore, international experts in the field of infant nutrition were invited to review the state of scientific research on DHA and AA, and to discuss the questions arising from the new European regulatory standards. Based on the available information, we recommend that infant and follow-on formula should provide both DHA and AA. The DHA should equal at least the mean content in human milk globally (0.3% of FAs) but preferably reach 0.5% of FAs. Although optimal AA intake amounts remain to be defined, we strongly recommend that AA should be provided along with DHA. At amounts of DHA in infant formula up to ∼0.64%, AA contents should at least equal the DHA contents. Further well-designed clinical studies should evaluate the optimal intakes of DHA and AA in infants at different ages based on relevant outcomes.
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