bluuebunny/crossref_metadata_2025_split huggingface dataset:
Brevity in Hadith Texts
Authors: Arrahawan Mohammad Said 
Published: May 2022

This paper attempts to determine, in cases where a prophetic tradition was reported in two different variants of differing lengths, which version originated first through an experimental focus on the report of Māʿiḏ’s lapidation, which followed his confession of adultery. It uses sanad-cum-matn analysis which relies on the examination and analysis of both the chains of narrators and the texts of versions under discussion. It argues against Schacht supposition that short versions of hadith always originate earlier and then elaborated at later stages through refinements and additions made by narrators. Similarly, it opposes Irene Schneider's assumption that long, detailed variants of a hadith are newer than their corresponding short versions. Schneider concludes that the short versions of a hadith could not have been based on an original “long version”.
Scientific Qur’anic Exegesis in Indonesia
Authors: Asnawi Aqdi Rofiq , Affani Syukron , Hakamah Zaenatul 
Published: May 2022

This paper investigates the impact of Islam’s relationship with science on the Qur’ānic interpretations given by Indonesian scholars. The discussion goes further to conclude their epistemology and approaches. It continues by examining the government’s role in providing a scientific Qur’ānic exegesis and several Indonesian institutions that deal with Islam and science integration in interpreting the Qur’ān. This study employs a qualitative research methodology by investigating all possible references and inducing the compiled data into sections based on predetermined research objectives. This article demonstrates that scientific Qur’ānic exegesis has grown in Indonesia since the 1960s and has been produced by Indonesian scholars in many works using various methodologies. Most of those works involved the integration of religion (Islam) and science. However, some of their epistemology tends to Islamisation, Qur’ānic justification or dealing with the concept of Islamisation of knowledge. The government uses scientific Qur’ānic exegesis to develop science and technology and propagate policies related to many sectors.
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THỰC HIỆN CHÍNH SÁCH, PHÁP LUẬT VỀ TÍN NGƯỠNG, TÔN GIÁO THEO TINH THẦN HIẾN PHÁP NĂM 2013
Authors: Nguyễn Thị Thu Trang 
Published: May 2022

Việt Nam là quốc gia đa tôn giáo với 95% dân số có đời sống tín ngưỡng và hơn 26,5 triệu tín đồ các tôn giáo. Hằng năm, có hơn 8.500 lễ hội tín ngưỡng, tôn giáo được tổ chức. Quyền tự do tín ngưỡng, tôn giáo ở nước ta được quy định rõ trong Hiến pháp. Ngày 18/11/2016 Quốc hội ban hành Luật Tín ngưỡng, tôn giáo, sau 5 năm triển khai trong thực tiễn, đối chiếu với những nguyên tắc trong Hiến pháp, bước đầu Luật Tín ngưỡng, tôn giáo đã đạt được một số kết quả đáng ghi nhận nhưng bên cạnh đó vẫn còn tồn tại một số những hạn chế, yếu kém cần khắc phục.
Gambaran Faktor-Faktor Perilaku Penyebab Kecelakaan Lalu Lintas Pengendara Sepeda Motor di SMAN 2 Gunung Putri Bogor Tahun 2019
Authors: Herlina Herlina , Utami Alda Safira 
Published: May 2022

Menurut data Kementerian Perhubungan selama 2016 terjadi 106.573 kecelakaan lalu lintas di seluruh Indonesia. Sebanyak 73,9 persennya melibatkan sepeda motor. Dilihat dari latar belakang pendidikannya, korban kecelakaan dengan pendidikan SMA sebanyak 138.995 orang pada 2016. Penelitian ini bertujuan untuk mengetahui gambaran faktor perilaku penyebab kecelakaan lalu lintas pengendara sepeda motor pada SMAN 2 Gunung Putri Bogor
Penelitian ini menggunakan desain yang bersifat kualitatif dengan pendekatan fenomologi. Jenis dan rancangan penelitian yang digunakan adalah deskriptif. Penelitian ini bertempat di SMAN 2 Gunung Putri Bogor Jalan Raya Kota Wisata No. 1, Ciangsana, Gunung Putri Bogor. Fokus penelitan pada faktor manusia, faktor kendaraan dan faktor lingkungan. Waktu penelitian dilakukan pada bulan April-Mei 2019. Sampel dalam penelitian kualitatif menggunakan informan pemilihan informan secara purposive sampling. Dalam penelitian ini sampel yang dipilih ada 6 orang yaitu informan kunci. Data yang diambil berupa hasil wawancara mendalam, observasi foto dan video. Analisis data menggunakan pendekatan triangulasi.
Faktor manusia: rata-rata berkendaraan saat umur 9 tahun, mereka telah memiliki SIM saat usia 17 tahun dan sebagian mengurus lewat biro jasa. Faktor kendaraan: Siswa tidak pernah mengalami rem blong karena setiap 3 bulan sekali selalu melakukan perawatan. Rata–rata siswa selalu mengganti ban setiap 6 bulan sekali. Siswa menyatakan lampu kendaraan siswa sudah otomatis dinyalakan pada siang hari. Faktor lingkungan: Di jalan yang rusak masih banyak siswa yang menyalip kendaraan lain. Siswa yang melewati jalur jalan yang licin siswa berkendara dengan kecepatan yang tinggi yaitu 60 km. Pada jalan tikungan siswa melewati jalan tersebut dengan kecepatan ada yang normal dan ada pula yang dengan kecepatan tinggi.
Gambaran Penerapan Sistem Tanggap Darurat Kebakaran Di Rumah Sakit Islam Jakarta Sukapura
Authors: Vestabilivy Evi , Maula Hifdziyatul 
Published: May 2022

Rumah Sakit merupakan salah satu tempat yang juga tidak lepas dari berbagai kemungkinan bahaya kebakaran. Oleh karena itu perlu juga dibuat suatu sistem tanggap darurat terhadap bahaya kebakaran yang baik, menyediakan peralatan tanggap darurat yang sesuai, serta melakukan uji coba secara periodik. Kebakaran rumah sakit juga pernah terjadi di Indonesia diantaranya kebakaran di Rumah Sakit Umum Dokter Sardjito Yogyakarta pada 6 Agustus 2017, kebakaran di Rumah Sakit Asih Serang, Banten akibat arus pendek listrik pada 29 juli 2009, kebakaran Rumah Sakit TNI Angkatan Laut Mintoharjo, Jakarta pada bulan Maret 2016 akibat korsleting listrik yang menyebabkan 4 orang tewas. Tujuan penelitian ini untuk mengetahui Gambaran Penerapan Sistem Tanggap Darurat Kebakaran di Rumah Sakit Islam Jakarta Sukapura.
Penelitian ini merupakan penelitian kualitatif dengan fokus penelitian untuk mengetahui Gambaran Penerapan Sistem Tanggap Darurat Kebakaran di Rumah Sakit Islam Jakarta Sukapura. Penelitian dilakukan di unit K3 Rumah Sakit Islam Jakarta Sukapura yang berada di jl. Tipar Cakung No.5 Sukapura, Jakarta Utara pada bulan Juni s.d Juli 2018. Teknik pengumpulan data menggunakan informan dan data diambil melalui wawancara mendalam, telaah dokumen dan observasi.
Secara keseluruhan RSIJ Sukapura telah melaksanakan sistem tanggap darurat dengan baik, Dimana sesuai dengan OSHAS 18001. Namun beberapa dari elemem sistem tanggap darurat masih belum sepenuhnya sesuai dengan KemenkesNo.1087/MENKES/SK/VIII/2010 Standar Kesehatan dan Keselamatan Kerja di Rumah Sakit.
Leaving Money on the Table(s): An Examination of Federal Income Tax Policy Towards Indian Tribes
Authors: Cowan Mark J. 
Published: May 2022

“When asked by an anthropologist what the Indians called America before thewhite man came, an Indian said simply, ‘Ours’”“[G]overnment’s view of the economy could be summed up in a few shortphrases: If it moves, tax it. If it keeps moving, regulate it. And if it stops moving,subsidize it.”Indian tribes are on the move. At least those that have opened casinos. Following decades of abject poverty, the advent and rapid expansion of Indian gaming has finally provided tribes with a viable economic development opportunity. Approximately 201 tribes run 321 gaming facilities that employ over 300,000 people. In 2001, tribal gaming operations generated revenue of $12.7 billion. This income goes untaxed at the tribal level since, for nearly forty years, the Internal Revenue Service (“IRS”) has taken the position that the income of Indian tribes is not subject to federal income taxation.
Capital Equipment Expensing: Incremental Tax Reform for a Transition Realization-Based Income Tax
Authors: Terry Charles T. 
Published: May 2022

Three years ago, I published an article that characterized the U.S. income tax as a specialized variant of a true income tax and dubbed it a “realization-based income tax” (RBIT). It analyzed then current cost recovery theory and policy with respect to equipment. The earlier article argued that normative cost recovery policy for a tax on capital income in a RBIT should exhibit two financial features: first, it should provide for the complete financial recovery of all capital invested in equipment; and second, it should financially measure any realized income produced by the investment in the equipment accurately. The earlier article evaluated three prototypical cost recovery approaches, and concluded that only immediate expensing produced financial characteristics consistent with those features of a normative realization-based income tax when applied to equipment purchases financed exclusively with “tax capital.”
Biometrics: Solving the Regressivity of VATs and RSTs with "Smart Card" Technology
Authors: Ainsworth Richard Thompson 
Published: May 2022

Biometric identifiers embedded in national identity cards puts a formerly impossible goal of consumption taxation within the grasp of policymakers for the first time. Never before has it been possible to design a broad-based, single-rate consumption tax that is truly and independentlyprogressive.No consumption tax has ever had all three of the critical attributes of a progressive consumption tax: a broad base, a single-rate, and measured relief for those in greatest need. Although economists have urged that a broad base and a single-rate be pursued over progressivity, most consumption taxes instead seek progressivity at the expense of both base and rate considerations.
The Case for Residency-Based Taxation of Financial Transactions in Developing Countries
Authors: Keinan Yoram 
Published: May 2022

The globalization process does not permit a country that wishes to be involved in this process to take an independent stand in choosing its tax system, especially with respect to financial transactions. Choosing tax rules that are unacceptable in the world’s leading countries could adversely affect an economy’s competitiveness in the world’s capital markets. The growth in international capital movements is a contributory factor in this respect.In 1923, a committee comprised of four economists submitted a report to the League of Nations that set forth the basic principles underlying international tax principles, most of which still prevail today. Upon the issuance of the League of Nations Report in 1923, two generally recognized regimes for international tax have emerged – residency (or global) and source (or territorial). In a residency-based tax regime, residents are taxed on their worldwide income. In a territorial regime, by contrast, residents are not taxed on foreign source income, and foreign taxpayers are taxed on income generated in the source country. Over the years, there has been a significant degree of convergence among countries; as of today, most tax jurisdictions, whether developed or developing, use both source and residence taxation to some extent. According to Professor Reuven Avi Yonah, most countries follow an “international tax regime” in both their internal laws and tax treaties.
Tax My Ride: Taxing Commuters in Our National Economy
Authors: Holcomb Morgan L. 
Published: May 2022

Located on the scenic St. Croix River, Hudson, Wisconsin is just a half-hour drive from the major metropolitan area of Minneapolis and St. Paul - "the Twin Cities" of Minnesota. Hudson is, therefore, a popular "bedroom" community for Twin Cities' workers. Those commuters, the Wisconsin residents who work in Minnesota, face taxation by two sovereign states: They are taxed by the state of Wisconsin on the basis of their residency in Wisconsin, and they face taxation by Minnesota on the income that was "sourced" or earned, in Minnesota. It is well-settled that both states are entitled to tax at least some portion of our Wisconsin commuters' incomes. What is less settled is the constitutional limit of the "double" taxation that can occur when two states claim to be the source of income, a situation that is happening with increasing frequency in our increasingly mobile, and telecommuting, population. If, for example, a Wisconsin resident worked for a Minnesota employer, but occasionally worked from home, both Wisconsin and Minnesota could claim to be the source of the income. If both states claim to be the source of the income, the commuter will be taxed twice on that portion of her income, a result that doubtless seems markedly unfair to our commuter. The question this article explores is becoming increasingly pressing. Demographic and work place trends, along with increasingly aggressive state revenue collection practices, combine to predict that the question of fair apportionment of individual taxation will only grow in importance.The article begins with a comparison of state taxation of individual and business income. Part II proceeds to explore the relevant constitutional norms: the dormant Commerce Clause and the Privileges and Immunities Clauses of both Article IV and the 14th Amendment. Part III synthesizes these Constitutional norms and their application to commuters. Part IV concludes with a discussion of the growing importance of this question and the avenues for possible resolution.
Slouching Towards a Consumption Tax and the End of Retirement Income Security
Authors: Stein Norman 
Published: May 2022

I presented a version of this paper at a 2003 symposium on public policy for retirement security at the Ohio State Moritz College of Law.In 2003, the Bush Administration proposed two ideas that I (and others) feared would undermine the retirement income security of millions of Americans. The first idea was to create two new tax-favored personal savings vehicles: the retirement savings account and the lifetime savings account. These tax-benefited accounts, which would have existed outside the employer-based retirement system and replace individual retirement accounts, would each have permitted annual contributions of $7,500 each, or $15,000 in the aggregate. (An individual could also have set up lifetime savings accounts for family members without earned income, into which he could contribute $7,500 annually.) The contributions were to be made on an after-tax basis, but the earnings would be exempt from income tax, a schemata based on the Roth IRA. The RSA would impose penalties on pre-retirement withdrawals; the LSA would not. These ideas did not find favor in the Congress and were generally opposed by the business community, organized labor, and liberal think tanks, for reasons I will summarize shortly. Nevertheless, the White House and members of Congress have introduced similar proposals in 2004, 2005, 2006, 2007, and 2008, and the President’s Advisory Panel on Federal Tax Reform adopted retirement and lifetime savings accounts as part of its blueprint for reform, which was released in late 2005. Thus, the idea of these new accounts retains political and intellectual currency, like the proverbial bad nickel, and they, or variations on them, are almost certainly to survive the end of the Bush presidency.
Congressional Unilaterla Tax Treaty Overrides: The "Latter in Time Doctrine" is Out of Time!
Authors: Wolff Professor Mark J. 
Published: May 2022

The current form of globalization has resulted in greater global economic integration and liberalization, political openness, and cultural and social acceptance. As the world economy continues to weaken national economic orders, and as nations become more dependent upon international trade, good relations between nations may provide greater global wealth and political stability. Global integration requires a “cooperative multilateralist” approach, encouraging international alliances, partnerships and institutions. The current global shift, however, finds the United States in a period of protectionism. As a result of 9/11, the United States has begun a strategy of preemption, one triggered at creating measures aimed at preventing substantial casualties to the U.S., whether military or economic. The actions taken in furtherance of this strategy, such as the invasion of Iraq without the consent of the Security Council, altered the perception of the United States around the world. Furthermore, these actions were in direct contradiction of Secretary of State Condoleezza Rice’s pledge to “support and uphold the system of international rules and treaties that allow us to take advantage of our freedom.”
Consolidating Foreign Affiliates
Authors: Cummings, Jr. Jasper L. 
Published: May 2022

Proposal for ChangeA:Consolidate Foreign AffiliatesCongress and the Treasury should seriously consider repealing section 1504(b)(3), thereby including as part of the consolidated filing group affiliated foreign corporations that are owned by the common parent and other members of the group. This act would expand the consolidated return to its logically proper scope and would end deferral (of U.S. taxation of active business income earned by foreign affiliates) based on the happenstance of corporate shells having been placed between them and their owners in the consolidated group. However, if the current debate over deferral, after consideration of the consolidation extension, ends in a decision to retain some sort of deferral, then consolidation of foreign affiliates still will produce a superior measurement of the entire business income without regard to legal structures. In conjunction with including foreign affiliates in the consolidated group, Congress can make a principled choice about how much of the foreign income of the group should be excluded from current (or any) taxation, based on income sourcing or some other administrable measurement.
Defining Income
Authors: Abreu Alice G. , Greenstein Richard K. 
Published: May 2022

More than half a century ago in Commissioner v. Glenshaw Glass, the Supreme Court defined "income," as used in section 61 of the Internal Revenue Code, as "undeniable accessions to wealth, clearly realized, and over which the taxpayers have complete dominion." The Code narrows the scope of income by providing for specific exclusions but, outside of those exclusions, the Code's own, self-referential definition-"gross income means income from whatever source derived" - seems to confirm the broad scope of the definition.The breadth of the Glenshaw Glass definition appears to be nearly co-extensive with the Haig-Simons definition of income, which is widely accepted as providing the theoretical foundation for the income tax. Accordingly, many tax professionals interpret the language in section 61 and Glenshaw Glass solely in light of the economic principles reflected in the Haig-Simons definition. The analytical structure for determining what is income appears clear and is generally treated as immutable. The analysis begins with the broad mandate of section 61 and Glenshaw Glass. As long as there is a realized accession in the economic sense within the taxpayer's dominion, Glenshaw Glass would seem to provide that there is income unless, pursuant to the very first words of section 61, there is an exclusion in the statute. From the time they are introduced to the tax law, students are taught this analytical structure, and by the time they become practitioners and then judges or scholars, it is second nature.
Work Product Immunity for Attorney-Created Tax Accrual Workpapers?: The Aftermath of United States v. Textron
Authors: Lischer, Jr. Henry J. 
Published: May 2022

United States v. Textron, Inc. has been a high-profile case involving the applicability of work product immunity to attorney-prepared documents known as "tax accrual workpapers." The Textron decision is worthy of careful analysis because it is the first decision at the Court of Appeals level to consider work product immunity for attorney-created tax accrual workpapers. The U.S. District Court ruled that work product immunity applied to the tax accrual workpapers, the First Circuit Court of Appeals ruled that work product immunity did not apply, and on May 24, 2010, the United States Supreme Court denied the certiorari petition in the case. Accordingly, the Textron decision is final, and it is appropriate to review the scope of work product immunity as it may apply to tax accrual workpapers. The denial of certiorari means that the lower federal courts must decide, without the benefit of Supreme Court guidance in Textron, whether work product immunity applies to attorney- prepared tax accrual workpapers.I conclude that attorney-prepared tax accrual workpapers technically do not and, as a matter of policy, should not qualify for protection as work product because of (1) the significant role of tax accrual workpapers in financial accounting and federal income tax reporting and (2) the specific statutory authority of section 7602 empowering the Internal Revenue Service (IRS) to collect information from taxpayers. I propose that courts embrace a doctrine of "tax exceptionalism" for purposes of work product immunity cases, and this doctrine acknowledges the unique public policy considerations that support effective tax administration. Permitting discovery of tax accrual workpapers raises significant fairness issues, but discovery of these workpapers is consistent with extant caselaw regarding work product immunity as well as with the purposes underlying work product immunity.
Understanding Consolidated Returns
Authors: McMahon, Jr. Martin J. 
Published: May 2022

Section 1501 allows all of the members of an affiliated group of corporations to elect to file a consolidated return. A consolidated return permits the includible members of an affiliated group of corporations to combine their incomes into a single return. The detailed rules for filing consolidated returns are found in regulations promulgated pursuant to a broad delegation of authority in section 1502 of the Internal Revenue Code. In general, the regulations reflect a “single entity” approach that attempts to treat the several members of a consolidated group in the same manner as divisions of a single corporation. This article explains the most important general principles governing consolidated returns and is intended to provide an overview of the consolidated return regulations for lawyers who are generally unfamiliar with the detailed rules. Among other topics, the article explains (1) the rules governing eligibility to file a consolidated return, (2) the computation of consolidated taxable income, including relevant limitations on the use of net operating losses, (3) intercompany transactions and distributions, (4) stock basis adjustments, and (5) earnings and profits calculations. It explains both the rules in the consolidated return regulations and the differences from the rules that otherwise would govern had the corporations not elected to file a consolidated return.
Unveiling an enigma from the Cerrado: taxonomic revision of two sympatric species of Apostolepis Cope, 1862 (Dipsadidae: Xenodontinae: Elapomorphini) from central Brazil
Authors: Entiauspe-Neto Omar M. , Koch Claudia , Guedes Thaís B. , Paredero Rafael C.B. , Tiutenko Arthur , Loebmann Daniel 
Published: May 2022

Apostolepis albicollaris and A. cerradoensis are two Elapomorphini snake species, described within a short timespan, from the Cerrado of central Brazil. In their brief descriptions, these two species were diagnosed from congeners largely based on highly variable external morphological characters. Interestingly enough, A. cerradoensis has remained known based on a single specimen since its description. Here, we present a reanalysis of both type specimens, as well as a careful examination of a large series of specimens formerly assigned to these species, based on the comparison of internal and external morphology. We conclude that both species are synonymous, providing evidence for the recognition of A. cerradoensis as a junior synonym of A. albicollaris. Furthermore, an account of its updated diagnosis, morphological variation, geographic distribution, hemipenial morphology, phylogenetic relationships and an osteological description are also provided. We also discuss its conservation status, suggesting that the species is under threat and qualifies to be listed as Vulnerable (VU ab(iii)), considering its rarity, small geographic range, and persistent environmental threats.