ShantanuT01/DACTYL-Pretraining huggingface dataset:
Introduction Milton Friedman formulated the theory that businesses have the moral obligation to make profit (Friedman 21). However, some companies go out of their way to ensure the maximization of profits through whichever means necessary, including tax evasion. The government’s prerogative is to ensure that companies run their businesses uninterrupted and pay taxes in return. Most governments encourage foreign investment by allowing companies incorporated in other countries to conduct trade in goods and services in their countries. The resultant outcome is bringing such goods and services closer to the people while attracting income for the government through taxation. However, governments should balance the two needs without jeopardizing income production for these companies. Consequently, the United States government has formulated rules that reduce tax evasion without necessarily interfering with the running of companies, thus keeping company productivity as high as possible. The government has enacted policies such as the rules regulating controlled foreign corporations (CFCs) and Passive foreign investment companies (PFICs) for this purpose. Some of the taxation policies apply to all corporations while others only apply to foreign parties according to 26 USC 163(j) (Miller 128). This paper looks at the impact of rules governing the two types of companies concerning the effects they have on investment in the US. It also discusses the impact of the rules on company policies for controlled foreign corporations, including shareholding policies, incorporation policies, and distribution of dividends, and redistribution of profits into capital. Controlled foreign corporations (CFC) Background Taxation forms the source of most of the government’s revenue. As such, the United States’ Treasury Department through its agency, the Internal Revenue Authority (IRS), ensures the maximization of tax revenue by exploring every avenue that legally allows it to collect taxes from individual citizens, residents, and corporations. Funds collected from taxation enable the federal governments to pay off their debts to other countries and corporations in addition to enabling the federal governments to improve security for everyone within their borders while fostering development through the provision of basic social amenities and infrastructure. On the other hand, most citizens, residents and corporations look for any legal loopholes that prevent them from paying taxes in order to generate as much income as possible and optimize on profits. Therefore, the government and its agencies should make policies that favor its tax collection activities, while facilitating as little interference as possible to the running of businesses (Arnold 86). Prior to 1962, the government did not charge any taxes on income that foreign corporations generated and distributed as dividends to shareholders, as long as the corporations derived such income from the US sources. The resultant effect was that companies incorporated in the US and American citizens would take advantage and defer their income by investing in foreign corporations, as income th
As Juniper, I would have felt tremendous hatred and rebellion for my master. Watching my mother being raped or whipped or punished would outrage me. The feelings of vengeance would be plaguing my mind. Speaking of liberty, how could anyone assault any human form or even any living form? The most primary thought which would occur to me as Juniper would be how could someone speak the line, “all men are created equal” , and still practice slavery in its worst forms? Being a slave with no life of your own, it is difficult to imagine any positive factors in my life. There would only be a negative impact. To imagine facing the atrocities of the master, including rape, physical torture, and the feeling of fear that one morning, one of the family members would be forcefully separated from you, is the most horrific. In the video excerpt, you learned that Juniper and other slaves represented a “new generation of black people” who were creating their own identity as African Americans. Cite some examples from the video that you found most interesting and/or surprising. You might also want to offer some comments about how this “separate culture” helped blacks endure their enslavement. This practice and preservation of culture enabled them to garner the strength and support needed to face their masters and also bear their slavery. What I found most surprising is the bargaining power that the slaves gradually developed over some time to lead their own lives and to spend their time pursuing the activities they desired. Also surprising was the fact that the slaves made their musical instruments and played music in their communities. This aspect of spending time with your community in pursuing a hobby or enjoying must have been a crucial and interesting factor in binding with their community members. Sharing and caring have indeed proved substantial in enabling them to stand up for their rights, over a while. Sandoval As Jupiter, I think that after watching many horrific scenes such as lynching, the cutting off of ears, rapes among women, and many more atrocities the ideas of the Declaration of Independence could be hard to achieve due to the importance of the Slaves in the aspect of farming and agriculture. The Slaves during those years did much to cope with those atrocities. Their coping strategy was to show love and affection within each other after a long hard work. I don’t think there are many positive things to talk about being a Slave with the exception that I (Jupiter) was working inside the home taking care of Jefferson. I although learn things that others were deprived of, such as being exposed to some important facts by listening to certain news before others knew. The negative factor is the deprivation of my liberty which was subjective to obey orders and watching my parents obeying orders as wel
Introduction Flamenco, a type of Spanish music and dance originated in the early eighteenth century, in the gypsy communities of southern Andalusia, particularly in the areas of Seville, Jerez and Cadiz. It is speculated that the word ‘flamenco’ originated from the Arabic words felamengu (itinerant peasant) or flahencon (collection of songs). Others feel that it refers to the Flemish (‘flamenco’) retinue that Charles I brought from Flanders to Spain (Rodgers and Rodgers 191). The Andalucian Gypsy came from the Punjab area of Northern India, so their pena (suffering) is said to be because of their exile from the ancestral home, hundreds of years ago. Rejecting this theory, there are some who attribute the origins of flamenco to Arabia, Sephardic Jews or Greeks. In the 1780s, all these explanations assume that the music of the indigenous Andalucians was combined with the music of the gypsies and came to be known as the flamenco music (Rodgers and Rodgers 191). Non-Gypsy artists such as Don Antonio Chacon (1869-1929), Manuel Torres (1878-1933) and Pastora Pavon ‘La Nina De Los Peines’ (1890-1969 are considered to be the founding fathers of flamenco cante (Martinez 22). However, even before the advent of recording, many professionals were performing Flamenco music and the most important among them was Silverio Franconetti (1823-1889) who was known during his lifetime as El Rey de los Cantaores Andaluzes – ‘The King of Andalucian Singing’ (Martinez, 22). With the passage of time, Flamenco as a music form became commercialized as an entertainment form and was hybridized with various other forms of music. But true flamenco is still kept alive in private party circles, clubs and Andalusian cante jondo festivals. Main body By the end of the 18 th century, Andalusia was a region where people suffered for centuries from religious oppression, dictatorial rulers, poverty and famines. This left people with deep pain and skepticism about life. Out of this misery, gypsies raised their voices in songs expressing their sufferings and soon the Cante Gitano became a way of life and way of communication with the world. Initially, flamenco remained within the confines of the gypsy families and coplas (texts of the songs) were handed down orally and the primitive forms of gypsy flamenco music included t
Introduction Disaster is anything that can cause negative impacts on people, society, and the whole community when it occurs. A crisis can take two major forms, which are natural or human-made. It is important to recognize the crisis and the measures that can be taken to handle them. Based on the emergency planner, writes a report to the organization’s senior managers to inform them about the impacts that the disaster has on people, infrastructure, environment, and reputation of the organization (Quiroz-Palma, del Carmen Penadés and Núñez 2019, 567). The other reason for writing the report is to inform the organization about its role in any given disaster. The following is a disaster management plan that will be discussing some of the important considerations in crisis management. Aims and Objectives There are several targets and objectives that this report will achieve. The first one is to inform the senior management about the impacts that a disaster may have on the general society. The report aims to analyze important organizations and their roles in disaster management. Lastly, the report is to analyze the plans that were used in resolving the incidence. Such objectives would be achieved by assessing the relevant reports from the airport emergency plan and plans used in handling the disaster. Description of the Disaster A passenger aircraft was involved in a crash at Hamad International Airport (HIA). The aircraft was carrying a total of 198 passengers on board, and it was close to the Terminal Building, Concourse B (Cantos no date). When it was nearing the sky bridge, the front tires disintegrated and resulted in the aircraft’s nose dropping and impacting the ground. Furthermore, the wings of the aircraft were damaged, leading to massive fuel spillage. An aircraft incidence can have wide-scale impacts depending on the place that such has occurred. In this particular incident, the aircraft was carrying a total of 198 passengers, and at the same time, others were around waiting to board other flights. When caution is not taken to address such an issue, it will be riskier for other individuals who have come to board other similar flights from the same company. Furthermore, it is a short-term disaster because of its human-made nature. Impacts on People The disaster will profoundly impact people whereby would result in the loss of lives. When the disaster has occurred, it would cost the lives of people inside the plane and the surrounding individuals. In most cases, plane crashes are among the worst forms of accidents which may happen within an environment surrounded by people. The other impact is that the plane crash would lead to mental problems, especially for the victims who survived the incident. Any form of incidence resulting from accidents and deaths of individuals would cause psychological problems to the survivors (Butler et al . 2020, 4). Anytime they remember the incident an
Governments’ capacity especially in the industrialized countries to even feed their citizens is increasingly decreasing and this is causing the richer countries to lease land in poorer countries such as Africa to grow food to feed their citizens. Unfortunately the said African land has not been spared by environmental pollution and the large-scale foreign food production is being done at the expense of the already depleted natural resources. Scramble for many lands by the upcoming economies is just adding salt to the injury and it is most of all a major contributor to the world’s devastating situation. Global environmental situation has deteriorated over time and in all aspects including air pollution, water pollution, land pollution, and noise pollution caused for example by railway, and aircraft and general manufacturing industry etc. Technological and civil development has seen the increase of all kinds of pollutions. A natural human being would have affected the environment as time went by, but it is clear from history that human entrance into the Iron Age was the beginning of environmental pollution albeit at an insignificant level. Increased usage of water and fire certainly increased the rate of pollution especially air pollution. It was however not until World War 2 that pollution really became a popular issue. Introduction Due to the depletion of natural forests, water catchments areas have been severely affected. In very severe cases, countries have ventured into non-conventional water resources like cloud seeding in order to at least induce some rainfall. Water harvesting has become a common practice in many countries and irrigation as traditionally known has now been changed forms to for example drip irrigation in order to minimize water wastage during the exercise. The increase of industrialization has over time made worse the water scarcity situation. This is because a lot of water is used in manufacturing plants which not only reduces water levels but pollutes the sources of water since the used waters from the plants are dumped into clean water sources like rivers. Air pollution has not only increased respiratory and cardiovascular diseases but has also affected the climatic conditions which in turn affect the rainfall levels (Gary, 2004). An increase in population has also not spared our environment. Due to increased food demand production, deforestation has taken place speedily over time. However scrabble for African land has worsened the situation since developed countries are leasing large pieces of land for the production of cash crops in the already infertile land. Many leaders have warned governments against deforestation for short term economic gains noting that though the environment can survive without human beings, humankind would not survive without the environment. Deforestation is not only blamed for water scarcity but for much more problems. It is said that deforestation is a leading cause of the greenhouse effect, extinction of both animal and pl
Introduction We live in an integrated society where various elements color our view and understanding of what goes on around us. As such, we each have different opinions and outlooks on life that to some extent define who we are. One of the factors that lead to our holding of certain opinions is our beliefs which may be a result of our upbringings, educational background, or our varied interests in life. It is some of these beliefs that at times dictate our perceptions in life, the relationships we maintain with others, or even the kind of decisions we make in our lives. My Beliefs In my life, four major beliefs particularly stand out. I believe that the family set up comprising of a father, mother and children is a most important institute for the society and its continuity should therefore be protected at all costs. I believe that the media is an important facet of civilization and its freedom is vital for the survival of a free and democratically governed society. I believe that it is the moral and social obligation of the government to work towards decreasing the income inequality that exists between the rich and the poor in society. I believe that religion is a deeply personal choice and as such, it should not lead to animosity amongst people nor should anyone be victimized for belonging to or not belonging to a certain religion. In this paper, I shall set out to give a detailed discussion of what I feel have been the major influences on my forming of these opinions. I shall review how my upbringing and education may have played a role in the formation and reinforcing of these opinions that I hold. My first belief which relates to the significance of the family set up is mostly a result of my own experiences with my family. While I was born in Los Angeles, I was brought up in China surrounded by my parents and other siblings. It is here that I witnessed firsthand the importance of the family which not only provided for my basic needs but also acted as a source of inspiration and moral support wherever I needed it. Throughout my life, my family has been close-knit and in my opinion, this has had a positive impact on all the members of the family as we were growing up. The concern that my parents exhibited in my progress at school and in any project that I undertook had a positive bearing on how I performed and in most times, it acted as a major motivating factor. My relationship with other members of the society was also from my younger years governed by my upbringing for it was through my parents that I learned social etiquettes such as being polite and courteous to others. It is for these reasons that I have come to appreciate the fact that the family is an imp
Human body relies on several food components in order to remain healthy. Vitamins play a significant role in keeping the body at its proper state. Vitamin C (ascorbic acid), in particular, has been identified as being one of the most frequently used and highly valued vitamins globally (Pressman & Buff, 2000). This vitamin group helps in fighting many diseases. The research paper provides the different recommended dietary allowance (RDA) for the children, adolescents, and the elderly. It also discusses the complications associated with inadequate RDA for vitamin C as well as the effects of excessive intake of the vitamin on the body. Furthermore, the paper explains the role of vitamin C in maintaining good health. Medical researchers have found that the amounts of vitamin C required by different age groups are never the same. The minimum recommended dosage per day, also known as the RDA, for the children, adolescents and the elderly has been established. For children aged between 4 and 10, they require about 40-45 mg of ascorbic acid. Adolescents aged 15-24 require between 45 and 60 mg of ascorbic acid. This dosage requirement, according to research, does not vary significantly between adult males and females who must also take in a minimum of up to 60 mg of ascorbic acid daily (Pressman & Buff, 2000). For pregnant and lactating women, it is recommended that they take between 75 and 95 mg of ascorbic acid daily. This ensures the safety of the unborn child as well as the developing baby. The elderly, however, do not need large amounts of vitamin C. The stated RDA only refers to the minimum possible amounts of vitamin C that can help in fighting scurvy, a disease caused by inadequate levels of vitamin C. In fact, research findings estimate that a healthy person should have an intake of about 200 to 500 mg of ascorbic acid each day (Cass & English, 2008). As already mentioned, low levels of vitamin C in the body mainly result in a deficiency disease called scurvy and can be clinically treated by increasing the levels of vitamin C in the body. Besides, lack of vitamin C can also cause hemorrhages below the skin surface resulting in soft skin that is easy to bruise. Moreover, inadequate vitamin C causes poor healing of wounds, the gums become soft and spongy which in turn loosen the teeth (Pressman & Buff, 2000). Lower levels of vitamin C in the body also cause edema which is characterized by the retention of water. General body weakness, indigestion, and bronchial infections may also be indicators of inadequate supply of vitamin C in the body. Excessive intake of vitamin C has been clinically established to be very harmful. Ascorbic acid is highly soluble in water and any excesses are lost through urine. Toxic levels cause gastrointestinal problems which worsen with continued intake. The levels at which the ascorbic acid become toxic vary significantly from person to person as well as age. Relatively lower levels of about 1000 mg can be toxic to some individuals while others can manage up to highs of about 25,000 mg daily. Vitamin C, therefore, plays a pivotal role in maintaining a heal
The film under analysis is called Whale Rider and focuses on the story of the Maori girl Pai who is interested in becoming the leader of her tribe. Throughout the movie, all the heroes are involved in tense confrontations and conflicts that are premised on cultural communication, loss of identity, and the importance of traditions. Although the role of tribe leaders is assigned to male representatives only, Pai believes that she is doomed to become the whale rider. The movie accurately reflects face-negotiation theory that relies on the conflicts that result in the confrontation of different cultures. According to this theoretical framework, the movie also provides different interpretations of self-image, “a face” that is evaluated by society striving to maintain their cultural values and norms. Hence, in the movie, the face is defined as the meaning of social self-worth. Pai’s aspiration to become the leader of the tribe contradicts the beliefs and traditions to which her grandfather adheres, but the heroine is confident in her destination and, therefore, she strives to maintain her identity and reconcile her individuality. In search of identity, the film introduces the minority culture that highly respects the sacred traditions of the Maori tribe. However, Pai still believes the gender differences should not be the obstacle to her becoming a tribe leader. Being sensitive to the realization of self-knowledge allows an individual to cognize the essence of successful facework interaction competence. In the movie, Pai tries to define her place in Maori culture, as well as reconcile her identity that does not always coincide with the firmly established traditions. According to Ting-Toomey, “face loss occurs when we are being treated in such a way that our identity claims are either being directly or indirectly challenged or ignored” i . Both at an individual and a collective level, face loss becomes the major risk of conflict emergence. In the movie, the nature of the conflict relies on the inability of individuals to maintain the cultural image. As an example, the movie highlights the major conflict between Koro Apirana and his granddaughter Paikea Apirana. Hence, Koro strongly believes that violating traditions is unacceptable because it violates the old customs and rituals, according to which only males can become leaders. Koro protects the collective cultural images and strives to hand his beliefs and outlooks over generations. In contrast, Pai is concerned with her identity because she feels that he could become the leader of her people, even though she is a female. Gender inconsistency does not prevent the main heroine from affirming her tribal identity and conquer her leading position in the tribe. Although modernity has brought significant contradiction to the Apirana’s family, it has a potent impact on the self-perception of all the heroes in the movie. As such, Pai’s father overtly rejects to become a member of the tribe and adhere strictly to the ideas and beliefs of his family history. Instead, he chooses the life of free artists and