As part of a study on the factors determining the lightfastness of dyes on cellulosic materials, a means of examining the physical state of direct dyes in viscose was developed which makes use of dyed ultrathin films as primary specimens in the electron microscope.When this method was used to examine the physical state of two direct dyes in viscose, their physical state was found to differ markedly. Aggregates of one dye could not be detected in the viscose films at a resolution limit of about 30 Å, whereas aggregates of the other dye were plainly visible in viscose films dyed under the same conditions. The apparently unaggregated dye exhibited considerably poorer lightfastness on rayon than the one which aggregated in viscose.The results suggest the use of this method of study to investigate the influence of the physical state of direct dyes in viscose on their lightfastness.
The combination of expanding international trade and climbing corporate income tax rates in the early part of this century required nations to evolve methods for reducing the level of international double taxation. While most countries came to rely upon a variety of techniques, two general approaches emerged to the taxation of the income of residents derived from foreign economic activity. Some countries adopted a territorial based system in which foreign source income is normally exempted from domestic tax. That system generally leaves the taxation of foreign income to the government within whose territory the activity occurs and thus avoids double taxation entirely. Other countries, including the United States, chose to impose their tax on the world-wide income of their individual citizens and residents and domestic corporations. That approach necessitated the development of specific mechanisms to reduce double taxation when the country within whose borders the income had been derived also imposed a tax on that income.The prevailing solution to this source of double taxation is for the residence country to allow its taxpayers to credit taxes paid to foreign jurisdictions against their domestic income tax liability. The extent to which such a foreign tax credit effectively relieves double taxation, however, depends in part upon the adequacy of the description of the foreign taxes that may be credited against the domestic tax liability. If the description is overinclusive, allowing too broad a range of foreign taxes to be credited, the foreign income will be taxed too lightly. Conversely, if the description is under-inclusive, double taxation will not be fully relieved and the foreign source income will be taxed more heavily than domestic income.
ment denies a basis adjustment to a limited partner, 5 or Congress enacts legislation prohibiting certain deductions, 6 the effect is the same: the purchaser of property is denied basis to the extent of his financing. The concurrent use of two systems has also caused severe problems in administering the tax laws. In particular, the provisions controlling the tax consequences for partnerships involved in debt-financed transactions have never been satisfactory. Recent litigation has demonstrated that the basis provisions are unworkable, 7 and Congress has directed the Treasury Department to revise those rules promptly. 8 Those revisions, in turn, will likely require a significant modification of the proposed regulations providing for the allocation of income and expense among partners.9 Before the Treasury Department makes any revisions, however, it should recognize that the source of the difficulties resides in the at-risk concept, 10 and it should inquire whether the perceived benefits of the at-. risk analysis justify the cost in confusion and complexity. This Article argues that the resulting cost is not warranted, and that the at-risk concept in any of its manifestations is wrong in principle. The Article also demonstrates that applying the traditional separate-transaction system to any bona fide transaction involving loans and loan proceeds will yield a correct income tax result. Since the greatest deviation from this system has occurred in the treatment of transactions involving
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