Promoting global social justice is an overarching policy goal for Swedish governments regardless of their ideological orientation. Sweden combines bilateral strategies with an active involvement in multilateral efforts toward those objectives. Additionally, public spending for development issues is comparable high. There has been a gradual shift from conventional aid to developing countries, mainly sub-Saharan countries, toward aid directed at countries that are closer to Sweden. This involves, for instance, promoting democratization and civil society in Eastern Europe. There are growing concerns about the effectiveness and efficiency of some foreign aid programs and the risk of aid being used for unintended purposes by actors in the receiving country. That said, the commitment to international solidarity and aid to developing countries remains very strong.
The post-2014 red-green government has launched a campaign of "feminist foreign policy" which has gained international attention. International solidarity has a gender dimension, the argument goes, which has long been ignored. This foreign policy approach has been introduced in different international venues such as the UN and the EU. The new government has also become known for showing less tolerance than its predecessors with what it describes as "medieval" punishment techniques employed in Middle East countries, something which has caused some diplomatic friction. More broadly, the return of the Social Democrats to government has reenergized Swedish foreign policy. It has become more visible, but also more controversial.
Pierre, Jon (ed) (2015), The Oxford Handbook of Swedish Politics (Oxford: Oxford University Press), esp. Section 7.
Assisting developing countries has broad support in Denmark. Indeed, according to the Center for Global Development's Commitment to Development index, Denmark is ranked first in respect to overall commitment to development, first in respect to fostering institutions and third when it comes to reducing the burden of poverty. When it comes to efficiency, Denmark sits in the middle among OECD countries. Nearly all political parties support Denmark's development efforts and want the country to remain highly ranked in comparison with other countries.
Denmark is one of only five countries in the world to contribute more than the U.N. target of 0.7% of Gross National Income (GNI) to development assistance. In 2011, Denmark contributed 0.85% of GNI to development aid. The new Liberal government, which came to power in June 2015, decided to reduce Danish development aid but will still live up to the U.N. recommendation of 0.7% of GNI. However, some of the funds have been redirected to address the increasing inflow asylum-seekers. There will be increased focus on the regions in the Middle East and Africa from where many refugees come. Denmark's humanitarian aid will not be reduced.
The priority areas of Denmark's development strategy are human rights and democracy, green growth, social progress, stability and protection. About 30% of Danish aid is provided through multilateral channels.
In May 2016, 40% of the Danes felt that it was very important to help people in developing countries and 49% felt that it was fairly important. At the time of the great influx of refugees in September 2015, 30% of the Danes supported giving more development aid, 35% the same amount, 28% less. Overall, there is still relatively strong support for development aid in Denmark.
The government's current development strategy for 2018 prioritizes: increased efforts in areas close to war and conflict; increased focus on migration, including the return of illegal migrants to their home countries; increased development financing by mobilizing private capital; and increased support for multilateral efforts for women and girls' sexual and reproductive health and rights. About 70% of Denmark's official development aid (ODA) is bilateral, the remaining 30% is multilateral.
OECD, Development Assistance Committee (DAC), Peer Review Denmark 2011. http://www.keepeek.com/Digital-Asset-Management/oecd/development/oecd-development-assistance-peer-reviews-denmark-2011_9789264117082-en#page1 (Accessed 18 October 2014).
Regeringens udviklingspolitiske prioriteter 2018, http://um.dk/da/danida/strategi%20og%20prioriteter/prioritetsplaner?sc_mode=normal (accessed 21 October 2017).
Estonia actively participates in international humanitarian interventions through the EU and UN. Between 2015 and 2017, Estonia served a second term of membership on the UN Economic and Social Council (ECOSOC), which has increased the country's profile and visibility in the field of humanitarian aid.
A renewed 2016 – 2020 strategy on Estonian development cooperation and humanitarian aid takes the UN's Millennium Development Goals (MDGs) as a starting point. The strategy contains objectives and main fields of activities, and identifies major partner countries. The priority partners are former Soviet Socialist republics (i.e., Georgia, Moldova, and Ukraine) and Afghanistan. Estonia is active in various fields, but special efforts are made in transferring knowledge in the policy areas of education, health and e-government. Dissemination of domestic expertise in implementing ICT in public administration and education are areas in which Estonia is a trendsetter. Between 2016 and 2017, Estonia actively participated in providing relief to war refugees in Syria and provided emergency assistance in Ukraine.
In parallel to government efforts, NGOs and private enterprises work in the field of international development. Awareness-raising campaigns in the fair-trade movement offer one example of NGO activity. Due to the country's open economic policy and the absence of protectionist measures, fair-trade products can be found in most Estonian supermarkets.
New Zealand is highly committed to tackling global socioeconomic inequalities. According to the Commitment to Development Index 2017 (Center for Global Development), which ranks 27 of the world's richest countries on their dedication to policies that benefit people living in poorer nations, New Zealand is ranked 10th. Its aid program is managed by the Ministry of Foreign Affairs and Trade. It is coherent and efficient in prioritizing economic development (New Zealand is ranked fifth of 41 countries by the Center for Global Development with regard to the quality of its development assistance), despite being criticized by some NGOs. Free access to global markets for developing countries is high on its agenda. The government openly argues for its development program to be used for diplomatic and trade outcomes, and not solely development outcomes. Geographically, New Zealand focuses on countries in the Association of Southeast Asian Nations (ASEAN) and in the South Pacific, although significant funding is channeled through multilateral and international agencies.
Aid Statistics – Donor Aid at a Glance: New Zealand: http://www.oecd.org/dac/stats/documentupload/NZL.JPG (accessed October 13, 2014).
International Development Policy Statement: Supporting Sustainable Development (Wellington: Ministry of Foreign Affairs and Trade 2011).
New Zealand Aid Programme: https://www.mfat.govt.nz/en/aid-and-development/our-approach-to-aid/ (accessed December 4, 2016).
The Commitment to Development Index 2017. Center for Global Development (https://www.cgdev.org/commitment-development-index-2017) (accessed 27 September 2017).
In absolute terms, Germany is the second largest global donor of development aid (behind the United States). Aid has increased substantially in terms of official development assistance (ODA) both because increasing spending abroad and financial assistance for refugees within a donor country are included. Relative to gross national income (GNI), Germany has now established itself significantly above the OECD average and, in 2016, reached the U.N. 0.7% spending target (OECD 2017).
The country's trading system is necessarily aligned with that of its European partners. In trade negotiations within the European Union, Germany tends to defend open-market principals and liberalization. This position is in line with the country's economic self-interest as a successful global exporter. For agricultural products in particular, the European Union's Common Agricultural Policy still partially shields European farmers from international competition, thus limiting the ability of developing countries to export their agricultural products to Europe. However, Germany has been more open than peers such as France to a liberal approach that would provide greater benefits to developing countries and emerging markets.
The dramatic increase in refugees arriving in Germany in 2015 has increased the German government's awareness of the importance of stable social, economic and political conditions in developing countries. This has had a clear budgetary impact: the 2017 draft federal budget, proposes to increase the resources of the Federal Ministry for Economic Cooperation and Development by 15% (€1.1 billion), with a particular focus on fighting the causes of flight in North Africa and helping Syria and neighboring countries (Bundesregierung 2016).
Despite the austerity measures that have been taken to correct the imbalances in public finances, Ireland has maintained its spending on overseas development assistance in the region of 0.5% of GDP since 2008. There is a special focus on countries in Sub-Saharan Africa and on poverty eradication, ending hunger and encouraging gender equality, good governance and human rights.
Ireland has consistently supported an international agenda that advances social inclusion. Its support for a fair global trading system is constrained by the overriding role of the EU in framing trading policy and to some extent by concerns about domestic self-interest with regard to certain sectors, including farming.
Norway is a leading contributor to bilateral and multilateral development cooperation activities, as well as to international agencies focusing on development issues. Many Norwegian NGOs play a prominent role in international aid.
Norway's activities in these areas actively seek to combat poverty, exclusion and discrimination. It is also engaged in global health issues, the promotion of global education and efforts to prevent climate change as well as promoting gender rights and good governance. On the other hand, it maintains a high level of protectionism with respect to the import of agricultural products.
As a response to the increased number of migrants that came to Norway during 2015, the amount of money allocated to developing countries will likely be reduced somewhat. At the same time, voters and politicians alike increasingly recognize the need for development aid in Africa and the Middle East in securing resilient, sustainable and fair development. Similarly, there is a growing awareness of the need for social support measures as part of creating a safe, secure society.
Despite regular objections from politicians, the United Kingdom has been one of the few countries, which has maintained a commitment to devote 0.7% of GNI to foreign aid. In 2016, only Sweden, Norway, Luxembourg, Denmark, Turkey, the United Arab Emirates and, for the first time, Germany did the same. Under the coalition government, this spending was ring-fenced against cuts and the recent spending review has reaffirmed the commitment.
Development assistance spending is coordinated by the Department for International Development, whose work is scrutinized by the newly created Independent Commission for Aid Impact.
In general, the United Kingdom is a proponent of open markets and fair access for developing countries, although an attempt in the late 1990s to espouse an ethical trade policy was subsequently quietly dropped.
However, although the UK government has ring-fenced international development aid, this generosity has not been extended to the millions of refugees who, escaping war and poverty, have arrived in Europe over the last year. The UK government has repeatedly refused to shelter any refugee who had already made it to Europe and was reluctant to take more than a few hundred vulnerable children following the closure of the Calais "jungle." Instead, the UK government has offered to accept 20,000 refugees from camps in Syria over the next five years. Compared to the number of refugees already living in the overcrowded registration and aid facilities of other EU countries, 20,000 is very little. While politically understandable in the context of the EU referendum and recent general election results, this position contrasts sharply to the otherwise generous approach to international aid policy.
Canada's government has a long history of supporting international efforts to promote socioeconomic opportunities in developing countries, and has shown leadership on critical issues such as nutrition and child health. Canada's share of official development assistance has declined in relative terms and was only 0.26% of gross national income (GNI) in 2016, ranking 18th in the world. In 2016, the federal government began a review of its existing aid policies, and has now reoriented the majority of international assistance to creating equal opportunities for women and girls in the world's poorest countries. Investments in gender equality are widely considered necessary to meet the Sustainable Development Goals.
A North-South Institute study makes the case that Canada's current framework guiding foreign-aid efforts – that is, the focus on improving aid effectiveness and accountability – is insufficient as an overarching framework guiding the country's approach to development. This is because the focus on aid effectiveness captures only a small part of Canada's engagement with the developing world. A broader vision that includes aid and non-aid policies is needed in order for Canada to improve the coherence of its development policy and be an effective actor in the international development sphere. In principle, Canada promotes a fair global trading system. In practice, domestic interests are often paramount. For example, the government vigorously defends Canada's agricultural marketing boards in trade negotiations, even though the removal of the trade barriers related to these boards would give developing countries better access to the Canadian market.
The Agencia Chilena de Cooperación Internacional para el Desarrollo (AGCID) under the Ministry for External Relations has been the national agency responsible for international cooperation, South-South and triangular cooperation since 1990. Its current Strategy for the International Development was defined for the period 2015-2018.
Chile formally follows and promotes the United Nations' Sustainable Development Agenda (Agenda 2030) and its 17 Sustainable Development Goals in its foreign policies. In practice, those criteria do not necessarily give direction when it comes to decision-making regarding international cooperation with developing countries in the region (Chile cooperates nearly exclusively with Latin American developing and emerging countries). In respect of promoting fair access to global markets, Chile offers virtually no subsidies to domestic producers, and does not maintain protectionist trade barriers to imports.
The Czech Republic is not a major player in international development and devotes a relatively low share of GDP to development aid. As a percentage of gross national income, official development assistance has stagnated in recent years. However, the Czech Republic has pursued a relatively coherent strategy of development cooperation with a clear focus on countries where its own experience of transition can be helpful. The Transition Promotion Program, a centerpiece of Czech development cooperation, puts strong emphasis on the promotion of democracy, human rights and civil society. While the Ministry of Foreign Affairs is the main coordinator of bilateral and multilateral development cooperation, a large number of public and non-governmental actors are extensively involved in the selection of program countries and the identification of priority sectors as well as in on-the-ground activities in partner countries. In addition to long-term programs, there is also humanitarian aid for current crisis areas. Also, the Ministry of Foreign Affairs has long striven to effectively involve the Czech private sector in development activities.
France has a long tradition of offering support to poor countries both in terms of financial support and promotion of policies in their favor. However, this should be qualified. First, France is reluctant to consider that free trade is one of the most effective instruments of support. As a consequence, France is often an obstacle to the lowering of tariffs and trade barriers, for instance in agriculture. Second, French aid is concentrated on African countries, where its economic interests have been traditionally strong. The temptation to link aid to imports from the donor country is quite common.
Within the framework of international organizations, France is active but for the above mentioned reasons, its policy preferences are deeply influenced by path dependency, such as colonization and the global network of French-speaking countries.
Lithuania's government participates in international efforts to promote socioeconomic opportunities in developing countries through its development-aid policy. Lithuania provides development aid to Belarus, Ukraine, Moldova and Georgia, as well as Afghanistan (where it is involved in the civilian-military mission) through its own development-aid and democracy-support program, as well as through the European Development Fund, to which it provides a financial contribution (representing 65% of the country's total development aid). Moreover, in 2011 Lithuania joined the World Bank's International Development Association, which provides loans and grants for anti-poverty programs. Although Lithuania committed to allocating 0.33% of its gross national product to development aid by 2015 as part of its contribution to the U.N. Millennium Development Goals, actual levels of government expenditure remain under the target, reaching 0.14% of GNI in 2016. In 2016, preliminary data indicated that development aid reached $58 million in absolute terms, representing an increase of 26% in real terms over 2014. It is hard to judge the real impact of Lithuania's development aid given the absence of independent evaluations. Over the last several years, Lithuania's aid has focused on Ukraine and other Eastern Partnership countries.
As a member of the European Union, Lithuania is bound by the provisions of the EU's common policy toward external trade. Although the European Union generally maintains a position of openness with regard to trade and investments, it has retained some barriers to market access and other measures that distort international competition. In rare cases, Lithuania has adopted measures within the European Union's external trade regime that restrict trade (e.g., along with other countries, Lithuania prohibited import of a specific genetically modified maize, a measure related to consumer- and environmental-protection concerns, rather than being based on new or additional scientific information about the impact of GMOs). Despite being a small and open economy and officially advocating open global trade policies, Lithuania has often aligned itself in trade discussions with the European Union's most protectionist countries, especially on the application of such instruments as antidumping duties. It has also supported trade protection in the farming sector, backing EU import duties on key agricultural products that hurt developing countries specializing in agricultural exports.
The Lithuanian Ministry of Foreign Affairs, Lithuanian development aid, 2013. http://www.orangeprojects.lt/site/newfiles/files/Lietuvos_vystomasis_bendradarbiavimas_2013.pdf.
OECD, Lithuania's Official Development Assistance (ODA), 2016: http://www.oecd.org/countries/lithuania/lithuania-official-development-assistance.htm.
Elsig, M., "European Union trade policy after enlargement: larger crowds, shifting priorities and informal decision-making," Journal of European Public Policy, 17:6, September 2010, p. 781-798.
The Swiss government has increased its development-aid contributions since 2000. Currently Switzerland's contributions are above average when compared to other mature democracies. The Swiss government has set the goal of spending 0.5% of its GDP on development aid in the long run and achieved that in recent years. In 2016, 0.54% of GNI was spent on development aid, excluding the costs of asylum it was 0.43%. Sustainable agriculture, decentralized governance, poverty reduction and vocational training are core issues driving Swiss development cooperation (SDC). In the countries where it supports projects or aid distribution, SDC has a good reputation for maintaining independence from home industrial interests and for making long-term commitments. Nevertheless, it is a small donor with limited impact. SDC is well embedded within international development agencies, and coordinates its activities with their agendas on issues such as poverty reduction, climate change and sustainable economic development. To a certain degree, SDC's activities differ from general patterns of Swiss foreign policy, which is more conventional. Foreign policy is mainly trade oriented, supporting policies of market liberalization through international agencies like the WTO. In this context, development cooperation policies have become controversial. Whereas the SVP criticizes development cooperation as ineffective and calls for SDC budget cuts, the policy network of Swiss private development-aid agencies advocate a shift in policy that involves the mitigation of north-south inequalities by revising trade arrangements that disadvantage developing countries.
Australia plays a significant role in the region with regard to promoting economic development and poverty alleviation in less developed countries, particularly in the Pacific. Australia is also a strong advocate of trade liberalization, especially in relation to agricultural products, which is critically important to economic development in most developing countries.
However, the 2014 government budget included cuts to foreign aid of 7.6 billion AUD over five years, which arguably represents a backward step in promoting economic opportunities in developing countries.
Due to its status as a middle power, Australia lacks leverage on some issues. It has been unable to provide a major impetus to further develop the multilateral trading system, for example. Australian governments have supported the multilateral trading system rhetorically, but have at the same time contributed to the weakening of the WTO by implementing a number of preferential trade agreements. Australia has concluded free-trade agreements (FTAs) with all major economies in Asia (ASEAN, South Korea, China and Japan).
The level of official development assistance (ODA) provided by Japan in 2016 increased by 12.7% as compared to the previous year. Part of the increase was earmarked for opening embassies in additional countries, following in the footsteps of China. However, in relative terms, Japan has typically underperformed compared to the OECD average. The quality of the aid provided has improved in recent years, but assistance has been increasingly aligned with Japan's broader external-security concerns, a trend which may be viewed critically from the perspective of potential recipients or indeed the development community at large. The country's 2015 Development Cooperation Charter stresses the principle of cooperation for nonmilitary purpose; the important role of partnerships with the private sector, local governments, NGOs and other local organizations and stakeholders; an emphasis on self-help and inclusiveness; and a focus on gender issues. These ODA guidelines also enable Japan to support aid recipients in security matters, for instance by providing coast-guard equipment.
In the 2015 – 2016 period, the government started a Partnership for Quality Infrastructure, through which it plans to contribute $200 billion by 2020 to projects all over the world. Many observers see the plan as a reaction to China's Belt and Road initiative, with the advantage that Japan can contribute its world-class technological competence.
Tariffs for agricultural products remain high, as are those for light-industry products such as footwear or headgear in which developing economies might otherwise enjoy competitive advantages. On the non-tariff side, questions about the appropriateness of many food-safety and animal- and plant-health measures (sanitary and phytosanitary measures) remain.
Regarding free trade, Mexico is supportive of open trade agreements and actively seeks good relations with any country that might counterbalance its heavy economic dependence on the United States. Mexico has also been active in financing international development, providing modest levels of foreign aid. Moreover, foreign policy continues to embrace the topic of south-south-cooperation and supports regional development projects. The Mexican government has also been a supporter of the U.N. Global Goals (Sustainable Development Goals) and Agenda 2030, launched in 2015.
However, Mexico could do more to promote and advance social inclusion beyond its borders. The treatment of Central American immigrants, and more recently, Haitians, needs to be greatly improved. Diplomatic relations between Mexico and its southern neighbors are very good, but there is room for improvement in trade treaties in the region and Mexico could lead efforts to increase the economic integration and global competitiveness of Latin America. An excessive dependence on trade with the United States has prevented Mexico from looking south.
Slovakia ceased to receive World Bank development aid in 2008, and has been a donor of development assistance ever since. In September 2013, the country became the 27th member of the OECD Development Assistance Committee. However, official development assistance (ODA) has remained substantially below the EU target of 0.33% of GNI. Slovakia's top priorities with regard to ODA, as formulated in an official strategy for 2014 – 2018, include education and health care as well as the strengthening of stability and good governance in regions and countries that are of special interest to Slovakia. In line with this strategy, Slovakia focuses its bilateral development cooperation on three countries (Afghanistan, Kenya and South Sudan) as well as on several countries in the Western Balkans (Former Yugoslav Republic of Macedonia, Montenegro and Serbia), Eastern Europe (Belarus, Georgia, Moldova and Ukraine) and Africa (Tunisia), which it shares similar experiences of transformation. In 2017, the Slovak government approved an extraordinary contribution of €1 million to the EU Emergency Trust Fund for Africa aimed at tackling causes of illegal migration.
South Korea is a relatively new donor in the field of development cooperation. In 2016, the country provided $1.96 billion in net official development assistance (ODA), representing 0.14% of gross national income (GNI). Increase in ODA spending stalled under the Park administration, and Korea failed to achieve its goal of increasing spending to 0.25% of GNI in 2015. It has set a new ODA target of 0.30% of GNI by 2030. Korea's aid also fails to meet the recommendations of the OECD Development Assistance Committee (DAC), for example when with respect to the share of grants and both untied and multilateral aid. It remains to be seen whether the Moon administration will revitalize Korean development cooperation.
With regard to activity supporting a fair global trading system, South Korea has shown weak initiative. It has largely focused on negotiating a number of preferential trade agreements with the European Union and the United States, as well as with many developing countries. Market access for products from developing countries also remains limited in Korea.
OECD, Development Co-operation Report. 2017.
During the period under review, Turkey used development assistance to advance social inclusion and development beyond its borders. The government expanded its annual official development assistance (ODA) disbursements considerably from $967 million in 2010 to $6.2 billion in 2016. Turkey, thus, has become one of the leading countries in humanitarian assistance in the world.
Turkey's development cooperation is provided in line with the Statutory Decree on the Organization and Duties of the Turkish Cooperation and Coordination Agency (TIKA). TIKA designs and coordinates Turkey's bilateral development cooperation activities and implements projects in collaboration with other ministries, NGOs and private sector partners. In 2015, Turkey provided the largest share of its bilateral development cooperation to Syria, Somalia, Kyrgyzstan, Albania and Afghanistan. The main sectors for Turkey's bilateral development cooperation were humanitarian aid and refugee support, governance and civil society, education, health care and population.
The United States is an important player in global social policy because it provides a large share of the world's development assistance. Relative to the size of its economy, however, its efforts lag behind those of most OECD democracies. For most of the postwar era, U.S. foreign aid has had four features that have reduced its impact on economic development and welfare in poor countries: It has been modest in amount relative to national income; it has been heavily skewed toward military assistance; it has not always been coordinated with assistance from international organizations; and – at least with regard to food assistance – it has often been designed to benefit U.S. agricultural, shipping and commercial interests along with aid recipients.
Presidents Bush and Obama have both made major efforts to reorient U.S. foreign aid. The Bush administration accomplished a transformation of aid policy by reducing the emphasis on military spending, increasing health-related assistance, and focusing economic assistance on countries with stable democratic political systems and a commitment to long-term pro-business development strategies. President Obama continued the Bush-era effort focusing aid efforts on economic development, food security and poverty. In 2016, Congress passed a bipartisan Global Food Security Act committing U.S. foreign policy to focus on hunger and poverty in developing countries. The Trump presidential campaign stressed economic nationalism and the president is pushing to reduce foreign aid by up to 37% and there are reports that some officials in the administration are seeking to merge USAID with the State Department.
Austria often gives rhetorical support to agendas seeking to improve the global social balance. However, when it comes to actions such as spending public money to improve development in poor countries, Austria is often slow to fulfill its promises.
Austria's role in the European attempt to control mass migration is overshadowed by the multifaceted phenomenon of migration. To distinguish between political asylum-seekers, war refugees and economic migrants (as would be, according to the legal norms, necessary), the general political tendency is to put all migrants in one basket. Austria's role in closing the land route to the European Union ("Balkan Route") has been seen (and promoted) only from the viewpoint of an immediate Austrian national interest – not as an all-European or global matter. The significance of global inequalities as the main reason for mass migration is mentioned usually only as a rhetorical ritual.
As an EU member state, Austria's position concerning tariffs and imports is defined by the European Union's position. This body also represents Austria in the World Trade Organization. To prevent certain agricultural products from entering the Austrian market, the Austrian media and political parties (including agricultural interest groups) use environmental rather than specifically trade-focused arguments.
The gap between political rhetoric and political activity with respect to socioeconomic opportunities in developing countries has grown wider during the period under review. Austrian politics and public discourse have reacted to the ongoing volatile economic and fiscal situation by concentrating even more on internal demands. The debate regarding the EU-U.S. negotiations concerning a transatlantic free trade agreement has been dominated by a parochial outlook with little room for global arguments. According to critics, Austria's standards are among the highest in the world and any free trade agreement would result in a decline in quality for Austrian consumers. Nonetheless, after some heated debates, the government has at last agreed to CETA, the Comprehensive Economic and Trade Agreement between Europe and Canada.
Until the onset of the economic crisis, Greece used to be active in assisting less developed countries, but later focused on managing its own national social policy problems. Still, under the crisis, Greece participated in all of the European Union's decision-making efforts related to global social policy. In 2016, Greece's development aid budget increased by 10.8% as it increased its contributions to the EU development budget. Yet, at 0.14% of GDP, Greek aid is far below the OECD average (0.32%).
Overall, because of the constraints of the ongoing economic crisis, Greece has not helped curb inequalities in developing countries, but has done more than its share to help people who arrive in Europe from developing countries. Even though the reception (refugee camps, and medical and social care) which Greece offers to incoming refugees is far from ideal, it continues to receive and help desperate people landing on Greek territory.
The engagement of the Italian government in promoting socioeconomic opportunities internationally is generally rather limited. Over the years, the Italian level of international aid has been among the lowest for developed countries, but has increased recently from 0.13% of GDP in 2012 to 0.26% in 2016, according to the OECD and other sources. A special sector where the current and past governments have displayed a significant activity is that of providing help at sea through the Italian navy for illegal immigrants crossing the Mediterranean Sea on unsecure boats belonging to traffickers. In order to address the rapid increase in immigration across the Mediterranean Sea and the humanitarian catastrophes produced by this increase, the Italian government has proposed an EU "immigration compact," which should strengthen long-term EU help to African countries and develop bilateral agreements for the regulation of migration.
On a more qualitative and organizational level Italy has stressed the importance of fighting hunger and developing food production and distribution. Probably because of this activism it hosts three major U.N. food agencies, the Food and Agriculture Organization (FAO), the International Fund for Agricultural Development (IFAD) and the World Food Program (WFP).
Development cooperation has become a more relevant issue in Poland since EU accession, even though it is still not a priority of the Polish government. While Poland became the 28th member of the OECD Development Assistance Committee (DAC) in October 2013, it remains one of its smallest donors. In October 2015, the Kopacz government had agreed to implement its new development program for 2016-2020 which aimed primarily to support projects with NGOs in Ukraine, Belarus, Georgia and Moldova, as well as projects in East Africa and South America for a total of PLN 1.5 billion annually. The new PiS government has paid less attention to development cooperation than its predecessor. At the EU-Africa summit that took place in Valetta, Malta on 12 November 2015, however, it promised to contribute €1 million to address reasons for migration from Africa.
OECD (2017): Development Cooperation Peer Review Poland 2017. Paris.
There has been virtually no change in this area vis-à-vis previous reporting periods. Foreign aid remains very much a secondary consideration in foreign policy, with the main interest being in economic diplomacy promoting the Portuguese economy and its exports. That does not mean that Portugal is disengaged – it still participates through the provision of foreign aid, especially in the Portuguese-speaking countries of Africa and East Timor. However, while there is some funding for foreign-aid projects, there is little concern with overarching aid policy, which means that coherence has not been as strong as it might be. This lack of interest has also percolated through to the design of international policies and the lack of international leadership in that regard. It must also be kept in mind that Portugal is a follower, not an international leader, and has very few resources. Therefore, while Portugal is supportive of good intentions, it is in fact marginal with regard to the implementation and design of foreign assistance.
However, if the question were to be shifted to include foreign involvement beyond the financial and economic sphere, then Portugal is a "supplier of security" through its fairly limited participation in U.N., NATO, and EU security- and humanitarian-support missions. Furthermore, in specific instances such as Guinea-Bissau, Portugal is relatively very active in attempting to stabilize national governments, promote security and ultimately promote development. Despite Portugal's limited resources, it is providing the first professional military education to the armed forces of Guinea-Bissau.
The European Commission, Special Eurobarometer 455 "EU Citizen's views on development, cooperation and aid. April 2017.
With EU accession in 2004, Slovenia's status changed from donor to recipient of official development assistance. However, Slovenia has not been very active in international efforts to promote equal socioeconomic opportunities in developing countries. The few initiatives that exist are mostly focused on the former Yugoslavia. The prevailing attitude is that Slovenia has its own measure of socioeconomic problems to tackle and that potential Slovenian international influence is negligible. Still, Slovenia's official development assistance comes close to the EU target and has risen substantially in recent years.
Ministry of Foreign Affairs (2017): International Development Cooperation of Slovenia. Ljubljana (www.mzz.gov.si/en/foreign_policy_and_international_law/international_development_cooperation_and_humanitarian_assistance/international_development_cooperation_of_slovenia/).
OECD (2017): Development Cooperation Report 2017: Slovenia. OECD: Paris, 126-129 (http://www.oecd-ilibrary.org/development/development-co-operation-report-2017/slovenia_dcr-2017-37-en).
Budget cuts severely restricted the funding available for policies and instruments designed to enhance Spain's influence abroad; development cooperation suffered, as did more general contributions to global public goods. Since 2009, the country's official development aid (ODA) budget has declined by 70%. Currently, Spain gives just 0.21% of its GDP (2017) to official development assistance. In November 2016, the Spanish parliament approved a non-binding resolution to increase ODA to 0.40% of GDP in 2020. Since 2011, the focus of Spanish international action has been more business-oriented. As a consequence, less political attention has been given to development and fewer contributions have been made to global public goods. In 2017, the multiannual Cooperation Director Plan (2013 – 2016) was still the basic planning element of Spanish cooperation policy seeking to improve the coherence of development cooperation with other policies (e.g., trade), fostering specialization and better aligning the country's efforts with other EU member states' development strategies.
From 2011 to 2014, Dutch real development aid (total budget minus 23% for increasing expenses for refugees and asylum-seekers) was cut to 0.7% of GDP or €4.5 billion, then to 0.52% of GDP or €3.5 billion in 2015, and to €2.7 billion in 2016. In addition, costs for climate policy will be allocated to development aid budgets. Expenditure on international conflict management has added to the diminishing state budget for development aid. In the Commitment to Development Index, which ranks the 27 richest countries, the Netherlands ranking has been generally stable, although it has fallen from two out of 21 countries in 2005 to four out of 27 in 2015.
Aid is no longer focusing on poverty reduction alone, but also on global sustainable and inclusive growth, and on success for Dutch firms in foreign countries. The driving idea is that "economic diplomacy" can forge a coalition between Dutch business-sector experts (in reproductive health, water management and food security/agriculture) and business and civil society associations in developing countries. No cutbacks in the areas of women's rights or emergency aid have been made. Good-governance aid will be focused on helping developing countries to improve taxation systems. Following OECD guidelines, there will be a reassessment of the negative side effects of Dutch corporate policies in developing countries.
The Dutch policy response to the recent refugee crisis has mimicked Denmark's efforts, seeking to discourage refugees from coming to the Netherlands.
All of this shows declining commitment by the Dutch government to global policy frameworks and a fair global-trading system; the aspiration is instead to link development aid to Dutch national economic- and international-safety interests.
The economic crisis has placed continued pressure on the government's development-aid efforts. International-development policies, which are now split between the federal and federated entities, are increasingly being seen as an instrument to help Belgian firms export to developing countries. Unrelated aid is being cut, and Belgium has repeatedly missed its own spending targets despite recognized Belgian expertise in the field, particularly in sub-Saharan Africa. At the international level, Belgium has been part of efforts to push for more fair-trade arrangements, but has not been an agenda-setter.
The Croatian government takes part in the activities of international organizations to which the country belongs; these are mostly in the field of international security and involve armed-forces personnel in various roles. The government does not have a well-developed international-development policy and is little more than a passive participant in most other joint international activities. Trade policy is mostly focused on regional and EU relations, with the government lacking an independent policy beyond this context. For trade issues related to international development, the government follows the policy of the European Union and other international organizations. Since joining the EU, Croatia's international assistance policy has improved. The National Strategy for Development Cooperation 2015 – 2020 has been adopted, and the country aims to increase its development aid to 0.33% of GDP by 2030. This includes funds for the European Development Fund, which distributes aid at the EU level.
Cyprus participates and contributes in development-cooperation programs within the context of its membership in major international organizations. Its main policy is tied to that of the EU as well as manifested through international-cooperation and bilateral agreements in various fields. Cyprus is a contributor to UNITAID, participates in financing mechanisms for climate change, and provides assistance for infrastructure development, social services including health and human development, and environmental protection. Its official development assistance (ODA) amounted to 0.1136% of GDP in 2012 with an ODA target set at 0.33% by 2015. However, the last update of the CyprusAid website was in 2013.
Actions and policies do not appear to form part of a specific national strategy; rather, they take place primarily within existing international frameworks. The government appears to have little agenda-setting ambition in terms of pursuing specific initiatives of its own design.
Israeli policy regarding global inequalities mainly consists of offering assistance in humanitarian, medical and financial aid to developing countries during emergencies. In recent decades, this aid has been expanded to technological and agricultural knowledge-sharing. For example, in May of 2016, the Ministry of Economy and the Israel National Cyber Bureau organized a workshop to teach and share the country's cybersecurity expertise with developing countries (such as Argentina, Mexico, Colombia, India, Zambia, Kenya, Côte d'Ivoire and Montenegro). The government's Center for International Cooperation (MASHAV) oversees cooperation with other developed countries, and is responsible for launching emergency-assistance missions.
Although Israel has signed a number of international cooperation agreements with parties such as the United Nations Industrial Development Organization (UNIDO), it is not considered to be a leader or an agenda setter with regard to global fair-trade policies. However, it is improving its regulatory structure to reflect international trade agreements and WTO standards. In response to the 2011 social protests, it dismantled some import barriers and has begun to eliminate and reduce import duties on items such as electrical appliances, textiles and apparel, and recently, many food items.
The Maltese government has very limited opportunities to help shape or advance social inclusion beyond its borders. What little influence of this kind it has acquired is related to its participation in international organizations (such as the UN and WHO) and EU Ministerial Councils. In 2004, Malta committed itself to allocate 0.33% of GNI to Official Development Assistance (ODA) by 2015. However, Malta's foreign affairs minister recently stated that Malta was pledging only €900,000 in 2017, even though the 2016 national contribution should have been around €30 million. Malta has also received criticism from CONCORD (a European confederation of Relief and Development NGOs) regarding the actual share of the funds that reach these developing societies at the grassroots level. An analysis of the 2016 funds indicates that a large percentage was put toward domestic use. Transparency in the distribution of funding may decline with the recent disbanding of the ODA advisory board. On the other hand, Malta is supportive of EU efforts to address the refugee crisis and is the only EU member state to have fulfilled its asylum relocation commitments, accepting 131 refugees and asylum-seekers. Moreover, through the EU, Malta contributes to the EU Emergency Trust Fund supported by the Joint Valletta Action Plan and the Malta Declaration during Malta's EU presidency in 2017. Private sources also contribute significantly to development projects in other countries. Indeed, 12 projects financed and/or implemented on a voluntary basis by Maltese Non-Governmental Development Organizations (NGDOs) have been selected for co-financing by the government in 2016. Malta is also attempting to take the lead in development education and has introduced a master's degree in humanitarian action, targeting field workers in the Middle East, North Africa and the Gulf region.
Malta's development policy attaches special importance to countries in the Horn of Africa and Sub-Saharan Africa, the main source of asylum-seekers and clandestine immigrants to Malta. Malta's development policy also seeks to assist with development in Mediterranean states, notably North Africa and the Palestinian territories, providing scholarships and other forms of aid. Malta also actively assists other small states through the Commonwealth by making available its acquired experience and expertise as a developed small island country. In general, Malta follows the lead of the European Union; its policies on tariffs are in line with those agreed to in Brussels.
Since 2015, Malta has used its role as Chair of the Commonwealth Heads of Governments Meeting to press for development in a number of areas, including polio eradication, financial support for poorer Commonwealth states, combating climate change and women rights. Malta also hosted the Commonwealth Local Government Forum in November 2017.
Romania remains a minor player on the global stage when dealing with issues of global inequality. In 2016, the Cioloș government put development assistance on a new footing. Among other things, Law No. 213/2016 created a new Agency for International Development Cooperation, "RoAid," which is responsible for implementing development cooperation and humanitarian aid-related activities. In 2016, official development assistance rose by 71% in real terms. Romanian bilateral development cooperation has focused mostly on Moldova, Turkey, Serbia, Ukraine and Syria. In 2017, the cooperation with Moldova has been strengthened through the Romanian Economy Minister's bilateral meetings with his Moldovan counterpart to discuss projects to further integrate the two countries' natural gas and electricity networks, noting the success of the Ungheni-Chisinau pipeline. Moldova's ailing political and economic systems, as well as its proximity to Romania and geopolitical importance to Europe vis-a-vis Russia make it an attractive area of political and economic engagement.
The promotion of equal socioeconomic opportunities in developing countries is not on the agenda of Bulgarian society and its government. Bulgarian officials take positions on this issue only when they are required to do so by the agendas of international bodies such as the European Union and the United Nations. On such occasions, the behavior of Bulgarian officials is reactive and not proactive. However, Bulgaria does not resort to protectionist trade barriers beyond the structure of such barriers imposed by the European Union, and does not impede or attempt to undermine efforts by the international community to promote equal opportunities in developing countries.
Hungary pays only relatively little policy attention to developing countries. The Orbán government adopted a strategy for international development cooperation and humanitarian aid for the period 2014-2020 in March 2014. Hungary's development cooperation focuses on countries which have a large Hungarian minority and strong trade links with Hungary (Serbia, Ukraine) or in which Hungary has been militarily involved (Afghanistan). About 80% of all funds go to Serbia and Ukraine. Hungary's net ODA has fallen short of the official EU and OECD targets and has further declined relative to GDP in recent years.
OECD (2017): Development Co-operation Peer Review Hungary 2017. Paris (http://dx.doi.org/10.1787/dcr-2017-24-en).
As a result of government austerity programs, funding for bilateral development cooperation was reduced to a minimum between 2009 and 2011. This reduction has meant that Latvia's ability to directly contribute to efforts to tackle global social inequalities has been negligible. In 2016, Latvia's official development assistance (ODA) expenditure was €19 million or 0.08% of GNI, down from €21 million or 0.21% GNI in 2015. Latvia has adopted a multi-year ODA strategy, which foresees increasing contributions to 0.33% of GNI by 2020.
Bilateral development cooperation focuses on the three top-priority countries of Georgia, Moldova and Ukraine.


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Faculty & Staff Honors
Faculty & Staff Honors November 2, 2016
UNC Faculty Honored with APHA's Lilienfeld Award for Excellence in Teaching Epidemiology
Dr. Victor Schoenbach, associate professor of epidemiology at the UNC Gillings School of Global Public Health, has received the Abraham Lilienfeld Award from the Epidemiology Section of the American Public Health Association (APHA). Dr. Schoenbach was recognized on Oct. 31, during the APHA's annual meeting, held Oct. 29 – Nov. 2, in Denver.
[Photo: Dr. Victor Schoenbach]
The award recognizes excellence in the teaching of epidemiology over the course of a career.
Dr. Schoenbach earned a master's degree in health education and doctoral degree in epidemiology at UNC, and joined the university's public health faculty in 1980. His research and teaching interests are focused upon minority health and minority advancement; prevention of HIV and other sexually transmitted infections; and social epidemiology and social justice. His online epidemiology textbook, available in English and Spanish, has been downloaded by thousands of people in countries all over the world, and his case studies have been used by faculty at other universities.
For more than two decades, Dr. Schoenbach has been a faculty adviser and strong advocate for the Gillings School's Minority Student Caucus (MSC) and its annual Minority Health Conference. Established in 1977, the conference is the oldest and longest-running student-led health conference in the U.S.
In 2012, in tribute to his long, dedicated service, the MSC named its afternoon plenary session "The Victor J. Schoenbach Health Disparities Keynote Lecture." UNC Diversity and Multicultural Affairs also recognized Dr. Schoenbach's dedication to social justice, presenting him with its Martin Luther King Jr. Unsung Hero Award in 2014.
The Lilienfeld Award is presented in memory of Dr. Abraham Lilienfeld, renowned teacher, scholar, and former chair of the Johns Hopkins Bloomberg School of Public Health's epidemiology department. One of the most influential figures in the development of epidemiology as a profession in the mid-20th century, Dr. Lilienfeld mentored many leading epidemiology researchers.
Previous awardees include several people now or formerly affiliated with the Gillings School, such as Dr. Sherman James, Dr. David Kleinbaum, Dr. Bill Jenkins, and former UNC dean Dr. Michel Ibrahim.
"Quite frankly, it's hard for me to think that my name belongs in such distinguished company except as an admirer, which I most assuredly am," Dr. Schoenbach said.
Dr. Schoenbach noted that he had read Dr. Lilienfeld's textbook at the start of his own career and had met him once. He praised prior awardees whose teaching had been influential on his own career, including Drs. Robert and Suzanne Fletcher and other honorees mentioned above.
"Of course, most of the credit [for the award] belongs to more than 230 co-instructors and teaching assistants, many of whom went on to be professors – and even university presidents," Dr. Schoenbach said. "It is they who made it possible for me to teach epidemiology to more than 6,000 students."
Read more: https://sph.unc.edu/sph-news/schoenbach-honored-with-aphas-lilienfeld-award-for-excellence-in-teaching-epidemiology/
November 2, 2016 "IU Bloomington Professor Honored with Hulman Health Achievement Award" November 2, 2016 "UNC-led Multicenter Study to Examine Metformin's Impact Upon Infant Health"

redpajama_set_name: RedPajamaCommonCrawl


It doesn't have to. Disc Makers' SoundLAB is the best value in the workflow of making a CD. The Mastering that costs you $499 at The SoundLAB can cost you anywhere from $800 to $2,500 at other post production studios. For a fraction of the cost of other major Mastering studios, The SoundLAB gives you access to equipment that will help make your music sound like the pros - our engineering staff has the gear and the talent to rival the best studios in the country. We'll make your music ready for commercial release and your project will receive the individual care and attention it deserves.


→ Papke, T., Huber, F., Geyer, G., Schmidt, M., & Merklein, M. (2019). Characterisation of the Tensile Bonding Strength of Ti-6Al-4V Hybrid Parts Made by Sheet Metal Forming and Laser Beam Melting. (pp. 361-370). Aachen: Heidelberg: Springer.
→ Hohmann, M., Hecht, D., Lengenfelder, B., Klämpfl, F., & Schmidt, M. (2019). Direct reconstruction of qualitative depth information from turbid media by a single hyper spectral image. In Proc. SPIE 10885, Optical Diagnostics and Sensing XIX: Toward Point-of-Care Diagnostics. San Francisco, US: SPIE.
→ Lengenfelder, B., Hohmann, M., Klämpfl, F., Waldner, M., Zalevsky, Z., & Schmidt, M. (2019). Ex-vivo, remote photoacoustic sensing using speckle-analysis. In Proceedings of the International Conference on Advanced Optical Technologies. Erlangen.
→ Papke, T., Junker, D., Schmidt, M., Kolb, T., & Merklein, M. (2018). Bulk Metal Forming of Additively Manufactured Elements. In 190.


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Findmypast Releases New Norfolk Records This Week
The following announcement was written by the folks at Findmypast:
Thousands of records added for the English county of Norfolk this Findmypast Friday
· A bumper release for newspapers, with 12 new titles and 74 updated titles
Norfolk Wills & Probate
Brand new to Findmypast this week, this collection has over 257,000 records covering the years 1301-1858. The records cover 14 Deaneries, including Norwich and Lynn. You should normally spot an ancestor's name year, residence and title, which will often include their occupation and birthplace.
Norfolk Banns and Marriages
Over 65,000 records have been added to this existing set, covering 1702-1923. You'll normally discover details such as the marriage year, parish, and often the father's first name. So, multiple generations could be unlocked with just one record.
(The rremainder of this announcement may be found at: https://www.findmypast.com/blog/new/norfolk-wills-probate-parish)


How Many Ways Can You Lose Your Charitable Contribution Deduction?
While we usually think of real property as the asset most often exchanged under Section 1031 of the Internal Revenue Code, the provisions of that are by no means limited to real property. It is not at all unusual for a taxpayer who owns a private airplane to structure an IRC Section 1031 exchange when he purchases a new airplane and sells his current airplane. Through a properly structured IRC Section 1031 exchange, the taxpayer can avoid paying tax on the gain realized from selling his current airplane in return for taking a tax basis in the new airplane that is the carried-over tax basis of his prior airplane, increased by the additional cash he spends to acquire the new airplane.
In order to qualify for IRC Section 1031 treatment, the aircraft to be sold must have been used by the taxpayer either in a trade or business or held for investment-related purposes. If the aircraft was used only for personal purposes, it will not qualify for an IRC Section 1031 exchange. The reality with most private aircraft is that they are used for a combination of business or investment and personal reasons: The airplane may be flown to business meetings and used to fly the family to a vacation destination.
In Chief Counsel Advice 201605017, the IRS addressed this dual use of private aircraft and concluded that the airplane could not be bifurcated into a business or investment asset and a personal asset. It was either one or the other. The Chief Counsel told the field office that if it concluded that the taxpayer's business or investment use of the aircraft was less than 50 percent of the total use, it should conclude that the aircraft was a personal use asset and did not qualify for IRC Section 1031 treatment. A footnote cautions that a finding of more than 50 percent business or investment use does not in itself automatically cause the aircraft to be considered a business or investment asset. No examples are given in which an airplane used more than 50 percent of the time for business or investment purposes should nevertheless still be considered a personal asset ineligible for IRC Section 1031.
The Chief Counsel Advice does not constitute legal authority that must be followed by taxpayers. It does, however, set forth a position that is likely to be adopted by IRS auditors in the field.
We have written extensively about the very strict rules that must be followed in order for a taxpayer to deduct a charitable contribution. We have repeatedly pointed out that the IRS and the courts are very unforgiving of even minor "foot faults." Taxpayers recently took extreme measures to lose an otherwise good charitable contribution deduction.
In Gemperle v. Commissioner (TC Memo 2016-1), the taxpayers donated a facade easement with respect to a certified historical structure in which they lived. One of the requirements to obtain a charitable contribution deduction for this donation is that the taxpayer obtain a qualified appraisal. IRC Section 170(h)(4) requires that the appraisal be obtained and "attached" to the taxpayer's tax return on which the contribution deduction is claimed. In this case, the taxpayers obtained the appraisal but they (or their return preparer) failed to attach a copy to their tax return.
Following an IRS audit that resulted in the deduction being disallowed, the taxpayers took the matter to the U.S. Tax Court. The Tax Court upheld the disallowance of the deduction and imposed the 40 percent substantial valuation misstatement penalty because the appraisal report was not attached to the taxpayers' income tax return. As we have written countless times, you must follow to the letter all the rules surrounding charitable contribution deductions. There is simply no margin for error in this area.
In a recent Internal Litigation Memorandum, the IRS found that a nonrecourse loan to a partnership containing certain "bad boy" guarantees required the loan to be treated as a recourse loan for federal income tax purposes. As a result, the tax basis resulting from the loan, and deductions related thereto, were allocable only to the partners who provided the guarantees. Debt that is treated as nonrecourse is allocated among all the partners for tax-basis purposes.
any borrower makes an assignment for the benefit of creditors, or admits in writing or in any legal proceeding that it is insolvent or unable to pay its debts as they come due.
Although the memo indicates that "one or more" of the conditions was sufficient to cause the otherwise nonrecourse loan to be re-characterized, the IRS informally advised that it was only condition 7 that caused the concern. The IRS views condition 7 — the guarantee in the event of an assignment for the benefit of creditors or admitting to being insolvent or an inability to pay debts as they become due — as a payment guarantee, indicating that lenders have been able to enforce these provisions in that capacity. According to the informal advice, the other bad-boy conditions in the memo are not an issue and do not cause a re-characterization.
Practitioners have been critical of the memo, even if it is limited to condition 7. There is little difference between condition 7 and many of the other conditions. They should all be considered contingent and extremely remote. If these conditions were not remote, it is unlikely the loan would be made.
The IRS normally cannot assess additional income tax against a taxpayer after three years from the date the tax return for the year in question was filed. Similarly, after that period a taxpayer can no longer amend his return to claim a refund. In order to prevent the IRS or the taxpayer from being "whipsawed" by inconsistent positions on the tax treatment of items, the IRC contains certain provisions that can extend the statute of limitations to prevent these inequities. These are often referred to as the "mitigation" provisions of the IRC. The rules are extremely complex, but we can illustrate a recent example of their use without getting bogged down in too much detail.
In Costello v. Commissioner (TC Memo 2016-33), a brother and sister were the beneficiaries of a trust created by their deceased father. The trust received distributions from an IRA the father had during his lifetime and distributed the amount received equally to the two beneficiaries. The trust reported the IRA distribution as income and took an offsetting deduction for the distribution to the beneficiaries, so the trust did not owe any tax. The beneficiaries reported the distribution as income and paid tax on it. This treatment was consistent, as the income had been subject to tax one time, at the beneficiary level.
On audit, the IRS determined that the income must be taxed to the trust and disallowed the deduction for the distribution to the beneficiaries. The trust paid the resulting income tax on the IRA distribution. The IRS made corresponding adjustments to the beneficiaries' returns and sent them refund checks. The treatment was still consistent. The IRA distribution had been taxed one time, now at the trust level.
Enter the mitigation provisions. The Tax Court determined that the IRS could benefit from the mitigation provisions because the trust and the beneficiaries, related parties, adopted inconsistent positions. The trust's claim that it was entitled to a distribution deduction was inconsistent with the beneficiaries not paying tax on the distribution, and resulted in a double exclusion of taxable income. The court determined that this circumstance was covered by the mitigation provisions, and the IRS was permitted to assess tax against the beneficiaries, even though the statute of limitations had expired for the year in which they received the distribution. A windfall for the taxpayers was averted.
The mitigation provisions are intended to be neutral and can also work for the benefit of taxpayers. Assume that in year one, a cash-method taxpayer erroneously includes in his tax return interest income that was accrued at the end of year one, but was not paid to the taxpayer until year two. Upon an audit of year two, the IRS requires the taxpayer to include the interest income item in year two and pay the resulting tax. By the time the audit is completed, the statute of limitations for year one has closed. Under normal circumstances, the taxpayer would not be able to obtain a refund of the tax paid in year one, so he would end up paying tax on the same income item in both years one and two, resulting in a double inclusion of taxable income. This result is inequitable and not intended. In this case, the mitigation provisions come to the aid of the taxpayer and allow him to obtain his year one refund. In this example, the IRS was the party maintaining the inconsistent position, as it required the taxpayer to pay tax on the income in year two after the taxpayer had already paid tax on the same income in year one.
If a taxpayer sustains losses from a "passive activity," those losses can only offset income from other passive activities and cannot be used to offset income from investments or from active businesses of the taxpayer. A passive activity is a business activity in which the taxpayer has an ownership interest but does not "materially participate." In addition, most activities involving the rental of property, such as real property, also constitute passive activities without regard to the level of the taxpayer's participation.
There are several ways in which a taxpayer can meet the "material participation" requirement, the most common of which is to spend over 500 hours in the activity during the year. A taxpayer can also materially participate by spending over 100 hours in the activity if no other individual spends more time than the taxpayer. In both cases the question often arises, how does a taxpayer prove how much time he spent? The best practice is to do what lawyers and accountants do. They keep time sheets where they record the matters on which they work each day and the amount of time they spend on each matter. Most of the working world, however, is not accustomed to keeping detailed time sheets.
In Leland v. Commissioner (TC Memo 2015-240), the taxpayer was a lawyer who also owned a farm. While the actual farming work was done by an area farmer under a crop-share arrangement, the taxpayer was still required to spend considerable time both working at the farm and on farm business. He sought to prove his material participation in farming activities by proving that he spent more than 100 hours and nobody else spent more time.
The record of the case shows that the taxpayer did not keep contemporary time sheets. The court noted that the regulations allow a taxpayer to prove his participation by any "reasonable means." In this case, the taxpayer reconstructed records of his participation in preparation for the trial by reference to a calendar he kept and credit card receipts and invoices for purchases he had made related to the farm. The taxpayer used this information to construct logs he presented to the court. He also testified at the trial regarding the time he spent on the farming activity. The court determined that the taxpayer met his burden of proof as to his own time. He was also able to prove that his tenant farmer spent less time than he did. The taxpayer was allowed to deduct losses from the farm against his other income.
While this taxpayer prevailed, we continue to believe that keeping contemporary time records is the better practice. Most people keep some kind of calendar. It is not much extra work to note in your calendar the amount of time you spend on an activity each day.
In Estate of Sarah D. Holliday v. Commissioner (TC Memo 2016-51), the IRS was successful in its attempt to include the decedent's share of investment assets held by a family limited partnership in her gross estate for estate tax purposes. The inclusion precluded the estate from obtaining the benefit of valuation discounts for lack of control and marketability that likely would have been allowed if the family partnership had been respected.
The partnership was formed in 2006. The decedent was the only family member who transferred any assets to the partnership. She transferred cash and marketable securities and obtained a 99.9 percent interest as a limited partner and a 0.1% interest as a general partner through a limited liability company of which she was initially the sole member. Following the formation of the partnership, the decedent sold her interest as the general partner to her two sons and made a gift of a 10 percent limited partnership interest to an irrevocable trust. These transfers left the decedent with an 89.9 percent interest as a limited partner.
Upon audit of the decedent's federal estate tax return, the IRS took the position that the assets transferred to the partnership by the decedent should be included in her gross estate under IRC Section 2036. This section includes in a decedent's gross estate any asset the decedent transferred during her lifetime if she retained the right to the possession or enjoyment of, or the right to the income from, the property. There is an exception, however, if the transfer of the asset was a bona fide sale for adequate and full consideration.
The Tax Court first looked to see if the decedent had retained one of the proscribed rights, noting that this retention could be either express or implied. The IRS argued, and the court agreed, that there was an implied agreement with the general partner that if the taxpayer ever needed a distribution, one would be made. One of the sons testified at the trial that no additional distributions were made because "no one needed one." The court concluded from this testimony that if the decedent needed a distribution, one would have been made. As a result, the court concluded that the decedent was "unconditionally" entitled to receive distributions in certain circumstances.
The court next had to determine whether the transfer was a bona fide sale for adequate and full consideration, noting that in the context of family partnerships, this means there must have been a significant nontax reason for the creation of the partnership that was an actual motivation for creation of the partnership and not just a theoretical justification. The transferor must also receive a partnership interest with value proportionate to the value transferred.
The decedent's estate offered three nontax reasons for the formation of the partnership. It first argued that the partnership would protect the decedent from extortion by trial attorneys if someone working at the decedent's home was injured. The court did not accept this reason as legitimate, noting that the decedent had never been sued, was living in a nursing home when the partnership was created and had substantial assets outside the partnership.
The estate next argued that the partnership would protect the decedent from the undue influence of caregivers. The court did not consider this a legitimate reason either, because the decedent's two sons were keeping a close watch over her and one of them had a power of attorney to conduct her financial affairs.
Finally, the estate said that the partnership would preserve the transferred assets for the benefit of the decedent's heirs. The court was not persuaded by this reason, in part because the decedent did not participate in any discussions regarding the formation of the partnership or what type of entity it should be. The court concluded that the transferred assets should be included in the decedent's gross estate, thereby depriving the estate of a multitude of valuation discounts.
The court also found there were additional factors that indicated there was no bona fide sale. First, the partnership was not the result of an arm's-length transaction because the decedent was the only initial party. Second, the partnership maintained no books and records and held no meetings. Third, various provisions of the partnership agreement that called for periodic distributions and compensation to the general partner were ignored.
We think this case is a closer call than many of the cases in which the IRS has prevailed. In this case, the taxpayer avoided a number of the common pitfalls. The partnership was not created on the decedent's deathbed, she did not transfer anywhere near all her assets and she received only one distribution prior to her death, which was a distribution that was shared by all the partners. She clearly did not need to rely on distributions from the partnership to pay her living expenses.
The court seemed to base its finding that the decedent retained the right to income on the language of the partnership agreement and an implied agreement with the general partner to make distributions whenever the taxpayer needed a distribution, which the court said gave her an unconditional right to receive distributions from the partnership. This case shows, yet again, how important it is to avoid prearranged or implied agreements to make distributions to the taxpayer. If there had not been an implied agreement, perhaps the court would have reached a different result if the general partner had full discretion over whether distributions were to be made, rather than being required to make distributions when funds were available.
Individuals who perform services are classified either as an employee or an independent contractor, depending on certain criteria. The more control the recipient of the services exercises over the manner in which the service provider performs his services, the more likely it is that the service provider will be classified as an employee.
The classification has a variety of consequences for both the provider and recipient of the services. For example, the service recipient must withhold income and payroll taxes from payments made to employees and must pay the employer share of payroll taxes. If the worker is an independent contractor, the recipient of the services does not have to withhold payroll and income taxes, or pay any payroll taxes on behalf of such worker.
For the service provider, there are benefits and detriments to each classification. A worker classified as an independent contractor must pay both the employer and employee shares of payroll taxes, so an independent contractor essentially pays double the payroll taxes of an employee. The main benefit to being classified as an independent contractor is that any expenses the worker incurs in connection with his performance of services can be deducted on Schedule C of his federal income tax return. Schedule C deductions reduce the worker's adjusted gross income and are not subject to the alternative minimum tax or any of the many deduction limitations to which itemized deductions are subject. Expenses incurred by an employee are deductible only as miscellaneous itemized deductions, which means they are not deductible in computing the alternative minimum tax, are subject to the 2 percent of adjusted gross income floor on itemized deductions and are subject to the phase-out of itemized deductions as adjusted gross income increases.
The classification of a film industry production worker for purposes of deducting his business expenses was recently at issue in Quintanilla v. Commissioner (TC Memo 2016-5). The taxpayer worked on more than 150 television commercials that were filmed during the years at issue. He reported his income and business expenses on Schedule C, taking the position that he was an independent contractor. The IRS said he was an employee and should have deducted his expenses as itemized deductions on Schedule A.
The Tax Court began its analysis by stating the overriding principle that "an independent contractor is one who works for another but according to his own manner and method, free from direction or right of direction in matters relating to performance of work save as to results." On most of the taxpayer's jobs, he was hired to build sets for the commercial shoots. He was expected to provide his own tools, which is one of the hallmarks of an independent contractor. On a typical project, the production company would give the taxpayer a sketch of the set that was needed, then he decided how best to build it. He also had the risk that he could lose money on a project, if his expenses exceeded the amount for which he had agreed to do the work. Also relevant was the fact that many production companies used his services; no single project took longer than a month to complete.
The primary factor favoring the IRS' position was that the taxpayer was a union member and many of his jobs were done for prices set through collectively bargained contracts. The taxpayer testified that he joined the union only to obtain health insurance benefits. He did not receive other union benefits, such as paid vacation time. Since the preponderance of the factors indicated that the taxpayer should be classified as an independent contractor, the court found in favor of the taxpayer.
Worker classification is a big-dollar issue that gets a lot of IRS attention. Most often it comes up on the employer side, when an employer classifies a large group of workers as independent contractors, and upon audit the IRS takes the position they should have been classified as employees. If the IRS prevails, the employer may owe payroll and withholding taxes for many previous years.
Another way we often see this issue arise is when a company is being sold. During the due diligence process, the buyer's legal and accounting advisors might determine that a large group of workers should have been treated as employees rather than as independent contractors. This concerns the buyer, because if the IRS audits the company, a large liability for payroll and withholding taxes could result. The buyer will always demand to be indemnified by the seller against such liability, and in addition may demand an escrow holdback of a portion of the purchase price for some period after the closing.
The worker classification issue demands caution because the consequences of an incorrect classification can be monetarily significant. An employer can get an IRS determination as to the proper classification of workers by filing Form SS-8. A worker who wishes to know if he has been properly classified can also file Form SS-8 and obtain a determination from the IRS.
— Marc Owens recently spoke at the Washington Nonprofit Legal & Tax Conference on the topic "IRS Audits: What to Expect When the Bear Comes Out of Hibernation." In April, he will speak at the 2016 Representing and Managing Tax-Exempt Organizations conference on the topic "Correcting Tax Mistakes: When and How?" The American Health Lawyers Association magazine, AHLA Connections, just published an article by Marc titled "Obergefell, Bob Jones and the IRS." Marc is a partner in our Washington office.
— Diara Holmes recently spoke at the Washington Nonprofit Legal & Tax Conference on the topic "Working With Company Foundations: Self-dealing Traps for the Unwary." In June, she will speak at the National Association of College & University Attorneys Annual Meeting on the topic "Federal Tax Issues in Higher Education." Diara is a partner in our Washington office.


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Home » R&B » Confessions
Release Date: 03.23.04
Record label: Arista
Genre(s): Rap, Hip-Hop, R&B, etc.
This is Not The Grass Roots
by: john reed
With the release of Confessions, Atlanta native Usher Raymond has gone from a mid-level soul/slow jam crooner to the biggest thing in current urban pop.
Confessions is jumping out of the CD bins, selling 1.1 million its first week and an additional 486,000 units in week number two. Not as strong as the initial week, but strong enough to keep Janet Jackson's Damita Jo at a disappointing (for her expectations, anyways) #2 on the Hot 100 chart.
Now, before we get too excited; realize that Confessions is a good album, but it does not merit the inconceivable sales figures. Obviously the ultra-hooky and constantly played "Yeah" did help in racking up the numbers (and big props to Lil Jon and Ludacris for helping with that), but most of the constructed work that is Confessions will not light up your house party any more than a drowsy ballad from Ashanti.
Yes, there is some clever work on the disc; "Take Your Hand," stands out with its sampling of old Philadelphia Soul tracks (who could go wrong there?) as does the guitar heavy git "Bad Girl" (which should be the obvious follow-up single to "Yeah"), as well as the Jimmy Jam/Terry Lewis produced "Superstar," which are in the same category of originality as "Yeah."
But the revelatory tracks, which mostly concern the reasons for his much covered split with R&B chanteuse Chilli (from TLC), deal with his infidelity to her, an unexpected pregnancy, and the fact that he is a womanizer worthy of the busted playa in Shaggy's "It Wasn't Me." The collected songs really make it seem as if Usher were publishing his very own tabloid rag.
With all the momentum from Confessions, Usher may very well end up being the heir apparent to the (now vacant) King of Pop throne (no Justin, you will never be the KOP…not matter what Rolling Stone proclaims). However, he has to overcome his vocal limitations and maybe avoid opening his personal diary to the universe, as sometimes confessing too much, can be painful. 14-Aor-2004 8:30 AM


text:
AI material that learns behaviors and adapts to changing conditions
by University of California, Los Angeles
Photo of a mechanical neural network (MNN). Currently, the system is about the size of a microwave oven, but the researchers plan to simplify the MNN design so that thousands of the networks can be manufactured on the micro scale within 3D lattices for practical material applications. Credit: Flexible Research Group at UCLA
Just like a pianist who learns to play their instrument without looking at the keys or a basketball player who puts in countless hours to throw a seemingly effortless jump shot, UCLA mechanical engineers have designed a new class of material that can learn behaviors over time and develop a "muscle memory" of its own, allowing for real-time adaptation to changing external forces.
The material is composed of a structural system made up of tunable beams that can alter its shape and behaviors in response to dynamic conditions. The research finding, which boasts applications in the construction of buildings, airplanes and imaging technologies among others, was published Wednesday in Science Robotics.
"This research introduces and demonstrates an artificial intelligent material that can learn to exhibit the desired behaviors and properties upon increased exposure to ambient conditions," said mechanical and aerospace engineering professor Jonathan Hopkins of the UCLA Samueli School of Engineering who led the research. "The same foundational principles that are used in machine learning are used to give this material its smart and adaptive properties."
When the material is placed in aircraft wings, for example, it could learn to morph the shape of the wings based on the wind patterns during a flight to achieve greater efficiency and maneuverability of the plane. Building structures infused with this material could also self-adjust the rigidity in certain areas to improve their overall stability during an earthquake or other natural or manmade disasters.
Short video (73 seconds) of a mechanical neural network learning to adjust its rigidity in response to applied forces. Credit: Flexible Research Group at UCLA
Utilizing and adapting concepts from existing artificial neural networks (ANNs), which are the algorithms that drive machine learning, the researchers developed the mechanical equivalents of ANN components in an interconnected system. The mechanical neural network (MNN), as the team called it, consists of individually tunable beams oriented in a triangular lattice pattern. Each beam features a voice coil, strain gauges and flexures that enable the beam to change its length, adapt to its changing environment in real time and interact with other beams in the system.
The voice coil, which gets its name from its original use in speakers to convert magnetic fields into mechanical motion, initiates the fine-tuned compression or expansion in response to new forces placed on the beam. The strain gauge is responsible for collecting data from the beam's motion used in the algorithm to control the learning behavior. The flexures essentially act as flexible joints among the moveable beams to connect the system.
An optimization algorithm then regulates the entire system by taking the data from each of the strain gauges and determining a combination of rigidity values to control how the network should adapt to applied forces.
In order to check the validity of the strain gauge-monitored system, the research team also used cameras trained on the output nodes of the system.
Early prototypes of the system exhibited a lag between the input of the applied force and the output of the MNN response, which affected the system's overall performance. The team tested multiple iterations of the strain gauges and flexures in the beams as well as different lattice patterns and thicknesses before achieving their published design that managed to overcome the lag and accurately distribute the applied force in all directions.
"Identifying the reasons why [the networks] failed to learn is important for understanding how to design MNNs that successfully learn," the researchers shared how they solved the problem through trial and error over the past five years.
Currently, the system is about the size of a microwave oven, but the researchers plan to simplify the MNN design so that thousands of the networks can be manufactured on the micro scale within 3D lattices for practical material applications. Aside from using the material in vehicles and construction materials, the researchers suggest MNNs could also be incorporated into an armor to deflect shockwaves, or in acoustic imaging technologies to harness soundwaves.
The paper's lead author Ryan Lee is a mechanical and aerospace engineering doctoral student and member of Hopkins' Flexible Research Group at UCLA. Erwin Mulder of the University of Twente in Enschede, Netherlands, also worked on the research.
More information: Mechanical neural networks: Architected materials that learn behaviors, Science Robotics (2022). DOI: 10.1126/scirobotics.abq7278
Journal information: Science Robotics
Provided by University of California, Los Angeles
Citation: AI material that learns behaviors and adapts to changing conditions (2022, October 19) retrieved 9 February 2023 from https://techxplore.com/news/2022-10-ai-material-behaviors-conditions.html
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UK Stampin' Up! Demonstrator | make beautiful cards | Crafty Hippy: New Catalogue Sneak Peek!
Sorry for the delay with this post... I haven't been trying to keep you all in suspense on purpose but I've had a really nasty sore throat and ear ache these last few days. After getting Labrynthitis at the beginning of the year and being unwell with it for weeks on end it seems that if I get a bit run down then my ear starts hurting again - cue lots of falling over as my balance is then out. So funny!
I'm feeling much better today thankfully, so I've had time to photograph the project I was going to show you. It's made with a NEW stamp set that will be in the new Annual Catalogue - so you're getting a little sneak peek of some of the goodies that will soon be yours.
The stamp set is called Sea Street and it features this lovely octopus, and the school of fish. The sentiment is one that will be sticking around (along with the matching dies); so you may recognise that (Itty Bitty Banners). The paper is from one of the new designer paper stacks, it's called "Moonlight" and will be available with all the the other new goodies from the 1st July 2014.
If you'd like a catalogue then please don't hesitate to get in touch and remember you can browse and/or buy Stampin' Up! products from the Official Online Webshop using the "Shop Online Now" button at the top of this blog (left hand side).


Martin Smith is the Director of Dartmoor Teaching School Alliance.
Collaboration between teaching schools alliances is going to be increasingly important if we are going to create the self-improving, school-led system that Daryll Chapman has talked about recently to members. Dartmoor TSA is fortunate to be in a strategic partnership with SWTSA. Both TSAs are keen to collaborate effectively to ensure member schools have the best support and opportunities. A good example of this partnership approach was the Data Leaders' and Teaching and Learning Leaders' Conferences that took place at ISCA Academy on Tuesday 6th December (see separate report). These events were organised by both Dartmoor TSA and SWTSA, led by experts from within the alliances and showcasing examples of excellent practice from across the two TSAs.
The December issue of our newsletter reflects the wealth of expertise that we have within our Alliance and the range of high quality activity taking place. As the level of activity increases, more and more of our outstanding practitioners are stepping up as system leaders. Our SLEs, for instance, are increasingly involved in delivering CPD to NQTs, Teachers and Teaching Assistants (see CPD offer for Spring term) and supporting school improvement. Our senior leaders are increasingly involved as facilitators of leadership development and network development. What's powerful about all this activity and the people driving it is the energy and engagement generated. This was palpable during the recent Outstanding Leadership of Education (OLE) course that we delivered (see separate article). And this is, I believe, the power of the school-led system - enabling the most effective schools and practitioners to share their expertise through dynamic training, coaching and facilitation.
Please can I extend my thanks to all our member school for their support and commitment. We are very proud to be leading your alliance. Have a great Christmas break and hope to see you all on 17th January at the next Members' Forum.


text:
O Museu Casa do Colono é um museu histórico-temático localizado na cidade de Petrópolis, no estado do Rio de Janeiro. Sua sede é uma casa em estilo germânico construída em 1847, por um imigrante alemão, Johan Gottlieb Kaiser, militar - ex-mercenário do Exército Imperial Brasileiro.

Localizada no quarteirão Castelânea, remontando à cidade de Kastellaum, local de origem de várias famílias que emigraram e colonizaram Petrópolis.

História
O Rio de Janeiro foi o primeiro estado brasileiro a receber imigrantes alemães em 1823, durante o Segundo Reinado. Do projeto urbanístico estabelecido pelo engenheiro Júlio Frederico Köhler, nasceu a cidade de Petrópolis que receberia estes imigrantes em 1837.

Essas terras foram arrendadas em sistema de foro e laudêmio, pago aos herdeiros de Dom Pedro II até hoje.

Arquitetura
A casa tem características das habitações da antiga Simmern e de aldeias às margens do Rio Mosel na Alemanha. Possui paredes de pau-a-pique com barro misturado a capim, ripas de coqueiro, madeira para o vigamento, seus alicerces são de pedra bruta e o teto de zinco, um reflexo do modo simples de vida dos primeiros colonos alemães.

Com essas características da época em que a cidade foi colonizada, só restou essa casa. Feita toda de encaixe, não possui nem pregos nem concreto.

A disposição dos cômodos também mostra a adequação dos imigrantes ao novo país. Na Alemanha, as casas rurais típicas normalmente eram construídas ao redor de  um fogão central, utilizado tanto para cozinhar como para aquecer devido ao inverno rigoroso da Europa. Já no Brasil, a casa foi adaptada para ter uma separação nítida entre sala, cozinha e banheiro.

Museu
O objetivo da atração é simular o modo de vida dos primeiros imigrantes que chegaram ao município. O museu ainda abriga móveis, objetos, utensílios de uso doméstico, fotografias, quadros e instrumentos pessoais usados no período.

O museu foi inaugurado no ano de 1976, através da iniciativa do historiador Gustavo Ernesto Bauer, após negociações com a proprietária da casa, a Sra. Anna Margarida (bisneta de Johann Gottlieb Kaiser) e com a Prefeitura Municipal de Petrópolis, que a desapropriou e comprou o imóvel para torná-lo museu.

Nas paredes estão fotografias mostrando as caçadas, os piqueniques, as bandas de música, tradições que foram incorporadas à vida da cidade. Os móveis ressaltam a necessidade de aproveitamento dos espaços devido ao número dos núcleos familiares e os terços indicam a prática de sua fé.

Em seu acervo, em torno de 336 peças doadas pelos descendentes dos colonos, encontra-se o cortador de repolho, muito utilizado para fazer o chucrute(típico prato alemão). Também tem um exemplar de um instrumento conhecido como 'enxó', utilizado para descascar os troncos de árvores. No móvel para toalete, a bacia e um jarro d'água retrata como era precário o banho. As louças inglesas, algumas tem dizeres em alemão, como 'Venha logo papai  que o café vai esfriar'. Em 2020, o acervo foi ampliado com doações de objetos pertencentes à colona alemã Ana Elisabeth Weber, da primeira leva de imigrantes. Entre as peças doadas, uma bíblia de 1876, um crucifixo antigo da família, de confecção artesanal, tesouras de 1899 usadas por modistas/costureira, fotografias e recortes de jornais de 1938 que citam Elisabeth.

Em 2019, foi inaugurado o projeto de revitalização da exposição do Museu Casa do Colono, com o intuito de dar uma experiência mais receptiva, atrativa e didática. O projeto foi financiado pelo Fundo Municipal de Cultura e o acervo conta com uma nova identidade visual em sua exposição, com painéis expositivos, vitrines, suportes museográficos e legendas bilíngues, contando a história da imigração germânica em Petrópolis e sua relevância para a formação da cidade. O museu também criou o evento café da manhã colaborativo de fim de ano, com o intuito de fortalecer e estreitar o relacionamento da comunidade com o museu, tornando um espaço de encontros e trocas de conhecimento. Para participar do café, o visitante somente precisa trazer um tipo de artigo alimentício para dividir com os outros participantes do encontro.

Em 2020, o Museu Casa do Colono foi beneficiado com recursos do fundo Ibermuseus. Foi o único brasileiro na lista, entre museus da Argentina, Bolívia, Colômbia e Uruguai.

Ver também
 Imigração alemã no Brasil
 Imigração alemã no Rio de Janeiro

Ligações externas
 Museu Casa do Colono

Museus de história do Brasil
Museus de Petrópolis
História de Petrópolis

redpajama_set_name: RedPajamaWikipedia