994 resultados para Generation-skipping transfer tax


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This paper looks at how automatic load transfer may be used as a possible planning tool to help deliver faster connections for customers. A trial on an area of overhead line Network is presented to show how improvements in % feeder utilisation may be realised by changing the location of the open point. The reported Network data is compared to calculated data under two different configurations over a two week trial period. The results show that ALT open point determination in the presence of generation is different from a load only circuit and that the open points may not be fixed with time. Looking at improvements in Network headroom may not be conducive to other improvements in the network such as loss reduction or improving voltage profiles.

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The FHA program to insure reverse mortgages has brought additional attention to the use of home equity conversion to increase income to the elderly. Using simulation, this study compares the economic consequences of the FHA reverse mortgage with two alternative conversion vehicles: sale of a remainder interest and sale-leaseback. An FHA insured plan is devised for each vehicle, structured to represent fair substitutes for the FHA mortgage. In addition, the FHA mortgage is adjusted to allow for a 4 percent annual increase in distributions to the homeowner. The viability of each plan for the homeowner, the financial institution and the FHA is investigated using different assumptions for house appreciation, tax rates, and homeowners' initial ages. For the homeowner, the return of each vehicle is compared with the choice of not employing home equity conversion. The study examines the impact of tax and accounting rules on the selection of alternatives. The study investigates the sensitivity of the FHA model to some of its assumptions.^ Although none of the vehicles is Pareato optimal, the study shows that neither the sale of a remainder interest nor the sale-leaseback is a viable alternative vehicle to the homeowner. While each of these vehicles is profitable to the financial institution, the profits are not high enough to transfer benefits to the homeowner and still be workable. The effects of tax rate, house appreciation rate, and homeowner's initial age are surprisingly small. As a general rule, none of these factors materially impact the decision of either the homeowner or the financial institution. Tax and accounting rules were found to have minimal impact on the selection of vehicles. The sensitivity analysis indicates that none of the variables studied alone is likely to materially affect the FHA's profitability. ^

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A RET network consists of a network of photo-active molecules called chromophores that can participate in inter-molecular energy transfer called resonance energy transfer (RET). RET networks are used in a variety of applications including cryptographic devices, storage systems, light harvesting complexes, biological sensors, and molecular rulers. In this dissertation, we focus on creating a RET device called closed-diffusive exciton valve (C-DEV) in which the input to output transfer function is controlled by an external energy source, similar to a semiconductor transistor like the MOSFET. Due to their biocompatibility, molecular devices like the C-DEVs can be used to introduce computing power in biological, organic, and aqueous environments such as living cells. Furthermore, the underlying physics in RET devices are stochastic in nature, making them suitable for stochastic computing in which true random distribution generation is critical.

In order to determine a valid configuration of chromophores for the C-DEV, we developed a systematic process based on user-guided design space pruning techniques and built-in simulation tools. We show that our C-DEV is 15x better than C-DEVs designed using ad hoc methods that rely on limited data from prior experiments. We also show ways in which the C-DEV can be improved further and how different varieties of C-DEVs can be combined to form more complex logic circuits. Moreover, the systematic design process can be used to search for valid chromophore network configurations for a variety of RET applications.

We also describe a feasibility study for a technique used to control the orientation of chromophores attached to DNA. Being able to control the orientation can expand the design space for RET networks because it provides another parameter to tune their collective behavior. While results showed limited control over orientation, the analysis required the development of a mathematical model that can be used to determine the distribution of dipoles in a given sample of chromophore constructs. The model can be used to evaluate the feasibility of other potential orientation control techniques.

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This thesis details the top-down fabrication of nanostructures on Si and Ge substrates by electron beam lithography (EBL). Various polymeric resist materials were used to create nanopatterns by EBL and Chapter 1 discusses the development characteristics of these resists. Chapter 3 describes the processing parameters, resolution and topographical and structural changes of a new EBL resist known as ‘SML’. A comparison between SML and the standard resists PMMA and ZEP520A was undertaken to determine the suitability of SML as an EBL resist. It was established that SML is capable of high-resolution patterning and showed good pattern transfer capabilities. Germanium is a desirable material for use in microelectronic applications due to a number of superior qualities over silicon. EBL patterning of Ge with high-resolution hydrogen silsesquioxane (HSQ) resist is however difficult due to the presence of native surface oxides. Thus, to combat this problem a new technique for passivating Ge surfaces prior to EBL processes is detailed in Chapter 4. The surface passivation was carried out using simple acids like citric acid and acetic acid. The acids were gentle on the surface and enabled the formation of high-resolution arrays of Ge nanowires using HSQ resist. Chapter 5 details the directed self-assembly (DSA) of block copolymers (BCPs) on EBL patterned Si and, for the very first time, Ge surfaces. DSA of BCPs on template substrates is a promising technology for high volume and cost effective nanofabrication. The BCP employed for this study was poly (styrene-b-ethylene oxide) and the substrates were pre-defined by HSQ templates produced by EBL. The DSA technique resulted into pattern rectification (ordering in BCP) and in pattern multiplication within smaller areas.

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Here, we describe gene expression compositional assignment (GECA), a powerful, yet simple method based on compositional statistics that can validate the transfer of prior knowledge, such as gene lists, into independent data sets, platforms and technologies. Transcriptional profiling has been used to derive gene lists that stratify patients into prognostic molecular subgroups and assess biomarker performance in the pre-clinical setting. Archived public data sets are an invaluable resource for subsequent in silico validation, though their use can lead to data integration issues. We show that GECA can be used without the need for normalising expression levels between data sets and can outperform rank-based correlation methods. To validate GECA, we demonstrate its success in the cross-platform transfer of gene lists in different domains including: bladder cancer staging, tumour site of origin and mislabelled cell lines. We also show its effectiveness in transferring an epithelial ovarian cancer prognostic gene signature across technologies, from a microarray to a next-generation sequencing setting. In a final case study, we predict the tumour site of origin and histopathology of epithelial ovarian cancer cell lines. In particular, we identify and validate the commonly-used cell line OVCAR-5 as non-ovarian, being gastrointestinal in origin. GECA is available as an open-source R package.

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Forced convection heat transfer in a micro-channel filled with a porous material saturated with rarefied gas with internal heat generation is studied analytically in this work. The study is performed by analysing the boundary conditions for constant wall heat flux under local thermal non-equilibrium (LTNE) conditions. Invoking the velocity slip and temperature jump, the thermal behaviour of the porous-fluid system is studied by considering thermally and hydrodynamically fully-developed conditions. The flow inside the porous material is modelled by the Darcy–Brinkman equation. Exact solutions are obtained for both the fluid and solid temperature distributions for two primary approaches models A and B using constant wall heat flux boundary conditions. The temperature distributions and Nusselt numbers for models A and B are compared, and the limiting cases resulting in the convergence or divergence of the two models are also discussed. The effects of pertinent parameters such as fluid to solid effective thermal conductivity ratio, Biot number, Darcy number, velocity slip and temperature jump coefficients, and fluid and solid internal heat generations are also discussed. The results indicate that the Nusselt number decreases with the increase of thermal conductivity ratio for both models. This contrasts results from previous studies which for model A reported that the Nusselt number increases with the increase of thermal conductivity ratio. The Biot number and thermal conductivity ratio are found to have substantial effects on the role of temperature jump coefficient in controlling the Nusselt number for models A and B. The Nusselt numbers calculated using model A change drastically with the variation of solid internal heat generation. In contrast, the Nusselt numbers obtained for model B show a weak dependency on the variation of internal heat generation. The velocity slip coefficient has no noticeable effect on the Nusselt numbers for both models. The difference between the Nusselt numbers calculated using the two models decreases with an increase of the temperature jump coefficient.

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This paper deals with heat transfer on a moving plate by mean of an impinging jet. Three different turbulence models are used and it turns out that Lam-Bremhorst model is in good agreement with measurements when Re is lower that 5000. In case of moving strip (ratio m=V strip/V jet lower than 1/3), there is almost no effect of m on Nusselt distribution in the stagnation region.

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Understanding the evolution of the direct and indirect pathways of allorecognition following tissue transplantation is essential in the design of tolerance-promoting protocols. On the basis that donor bone marrow-derived antigen presenting cells are eliminated within days of transplantation, it has been argued that the indirect response represents the major threat to long term transplant survival, and is consequently the key target for regulation. However, the detection of MHC transfer between cells, and particularly the capture of MHC:peptide complexes by dendritic cells, led us to propose a third, semi-direct, pathway of MHC allorecognition. Persistence of this pathway would lead to sustained activation of direct pathway T cells, arguably persisting for the life of the transplant. In this study, we focused on the contribution of acquired MHC class I, on recipient DCs, during the life span of a skin graft. We observed that MHC class I acquisition by recipient DCs occurs for at least one month following transplantation and may be the main source of alloantigen that drives CD8+ cytotoxic T cell responses. In addition, acquired MHC class I-peptide complexes stimulate T cell responses in vivo further emphasizing the need to regulate both pathways to induce indefinite survival of the graft.

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Traditional organic chemistry has long been dominated by ground state thermal reactions. The alternative to this is excited state chemistry, which uses light to drive chemical transformations. There is considerable interest in using this clean renewable energy source due to concerns surrounding the combustion byproducts associated with the consumption of fossil fuels. The work presented in this text will focus on the use of light (both ultraviolet and visible) for the following quantitative chemical transformations: (1) the release of compounds containing carboxylic acid and alcohol functional groups and (2) the conversion of carbon dioxide into other useable chemicals. Chapters 1-3 will introduce and explore the use of photoremovable protecting groups (PPGs) for the spatiotemporal control of molecular concentrations. Two new PPGs are discussed, the 2,2,2-tribromoethoxy group for the protection of carboxylic acids and the 9-phenyl-9-tritylone group for the protection of alcohols. Fundamental interest in the factors that affect C–X bond breaking has driven the work presented in this text for the release of carboxylic acid substrates. Product analysis from the UV photolysis of 2,2,2-tribromoethyl-(2′-phenylacetate) in various solvents results in the formation of H–atom abstraction products as well as the release of phenylacetic acid. The deprotection of alcohols is realized through the use of UV or visible light photolysis of 9-phenyl-9-tritylone ethers. Central to this study is the use of photoinduced electron transfer chemistry for the generation of ion diradicals capable of undergoing bond-breaking chemistry leading to the release of the alcohol substrates. Chapters 4 and 5 will explore the use of N-heterocyclic carbenes (NHCs) as a catalyst for the photochemical reduction of carbon dioxide. Previous experiments have demonstrated that NHCs can add to CO2 to form stable zwitterionic species known as N-heterocylic-2-carboxylates (NHC–CO2). Work presented in this text illustrate that the stability of these species is highly dependent on solvent polarity, consistent with a lengthening of the imidazolium to carbon dioxide bond (CNHC–CCO2). Furthermore, these adducts interact with excited state electron donors resulting in the generation of ion diradicals capable of converting carbon dioxide into formic acid.

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The article introduces the concept of E-Science and its importance in the generation of knowledge. This article also stresses the need to transfer that knowledge, before this, the School of Library and Information Science at the University of Costa Rica could gothrough such means as the online magazine E-Ciencias de la Información.It explains why we chose the form of electronic publication and describes the development strategy, architecture design and technological requirements. The article concludes that electronic publications have penetrated hard in the academic world and are increasingly cited, so that their contribution as vehicles for dissemination of knowledge is undeniable.

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Rather often we have to confront with the pessimistic views on the future of the family business. Contrary to these prognosis, the FB is not only present but also improving its position in the global economy and playing a key role in the European economy too. They represent 60 % of employment and more than 60 million jobs in the private sector. Among many internal challenges of FB in the five years’ time, the importance of the ‘company succession’ is increasing together with the renewing technology and ‘attracting the right sills/ talents’ (Global Family Survey, 2015). This article is focusing on the transfer of socio-economic wealth (SEW) as a key intangible asset within the intergenerational changes in the FB. The paper outlines the various concepts (narrow vs. broad) of the SEW and special attention is paid to the risk prone [taken] and risk adverse entrepreneurial attitudes. In this relation, the authors made distinction between the ‘opportunity’ and ‘necessity entrepreneurs’. Using empirical experiences based on multi-site company case studies in the three INSIST project countries, the various sub-sections are focusing on the transfer of the following key components of the SEW to the next generation: trust-based social-system, generic human values (i.e. openness, mutual respect, correctness, reliability, responsibility etc.) and ‘practice based – embedded collective knowledge’. Key lesson of this analysis is the following: transferring physical assets in the succession process seems to us less important than the transfer of the intangible one embedded in the company’s culture community. Further systematic national and international investigations – combining quantitative and qualitative research tools – are necessary to acquire more accurate picture on the impacts of transferring both intangible and tangible assets in the succession process in the FB.

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Colloidal stability and efficient interfacial charge transfer in semiconductor nanocrystals are of great importance for photocatalytic applications in aqueous solution since they provide long-term functionality and high photocatalytic activity, respectively. However, colloidal stability and interfacial charge transfer efficiency are difficult to optimize simultaneously since the ligand layer often acts as both a shell stabilizing the nanocrystals in colloidal suspension and a barrier reducing the efficiency of interfacial charge transfer. Here, we show that, for cysteine-coated, Pt-decorated CdS nanocrystals and Na2SO3 as hole scavenger, triethanolamine (TEOA) replaces the original cysteine ligands in situ and prolongs the highly efficient and steady H2 evolution period by more than a factor of 10. It is shown that Na2SO3 is consumed during H2 generation while TEOA makes no significant contribution to the H2 generation. An apparent quantum yield of 31.5%, a turnover frequency of 0.11 H2/Pt/s, and an interfacial charge transfer rate faster than 0.3 ps were achieved in the TEOA stabilized system. The short length, branched structure and weak binding of TEOA to CdS as well as sufficient free TEOA in the solution are the keys to enhancing colloidal stability and maintaining efficient interfacial charge transfer at the same time. Additionally, TEOA is commercially available and cheap, and we anticipate that this approach can be widely applied in many photocatalytic applications involving colloidal nanocrystals.

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Natural Language Processing (NLP) has seen tremendous improvements over the last few years. Transformer architectures achieved impressive results in almost any NLP task, such as Text Classification, Machine Translation, and Language Generation. As time went by, transformers continued to improve thanks to larger corpora and bigger networks, reaching hundreds of billions of parameters. Training and deploying such large models has become prohibitively expensive, such that only big high tech companies can afford to train those models. Therefore, a lot of research has been dedicated to reducing a model’s size. In this thesis, we investigate the effects of Vocabulary Transfer and Knowledge Distillation for compressing large Language Models. The goal is to combine these two methodologies to further compress models without significant loss of performance. In particular, we designed different combination strategies and conducted a series of experiments on different vertical domains (medical, legal, news) and downstream tasks (Text Classification and Named Entity Recognition). Four different methods involving Vocabulary Transfer (VIPI) with and without a Masked Language Modelling (MLM) step and with and without Knowledge Distillation are compared against a baseline that assigns random vectors to new elements of the vocabulary. Results indicate that VIPI effectively transfers information of the original vocabulary and that MLM is beneficial. It is also noted that both vocabulary transfer and knowledge distillation are orthogonal to one another and may be applied jointly. The application of knowledge distillation first before subsequently applying vocabulary transfer is recommended. Finally, model performance due to vocabulary transfer does not always show a consistent trend as the vocabulary size is reduced. Hence, the choice of vocabulary size should be empirically selected by evaluation on the downstream task similar to hyperparameter tuning.

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Unmanned Aerial Vehicle (UAVs) equipped with cameras have been fast deployed to a wide range of applications, such as smart cities, agriculture or search and rescue applications. Even though UAV datasets exist, the amount of open and quality UAV datasets is limited. So far, we want to overcome this lack of high quality annotation data by developing a simulation framework for a parametric generation of synthetic data. The framework accepts input via a serializable format. The input specifies which environment preset is used, the objects to be placed in the environment along with their position and orientation as well as additional information such as object color and size. The result is an environment that is able to produce UAV typical data: RGB image from the UAVs camera, altitude, roll, pitch and yawn of the UAV. Beyond the image generation process, we improve the resulting image data photorealism by using Synthetic-To-Real transfer learning methods. Transfer learning focuses on storing knowledge gained while solving one problem and applying it to a different - although related - problem. This approach has been widely researched in other affine fields and results demonstrate it to be an interesing area to investigate. Since simulated images are easy to create and synthetic-to-real translation has shown good quality results, we are able to generate pseudo-realistic images. Furthermore, object labels are inherently given, so we are capable of extending the already existing UAV datasets with realistic quality images and high resolution meta-data. During the development of this thesis we have been able to produce a result of 68.4% on UAVid. This can be considered a new state-of-art result on this dataset.

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Protocols for the generation of dendritic cells (DCs) using serum as a supplementation of culture media leads to reactions due to animal proteins and disease transmissions. Several types of serum-free media (SFM), based on good manufacture practices (GMP), have recently been used and seem to be a viable option. The aim of this study was to evaluate the results of the differentiation, maturation, and function of DCs from Acute Myeloid Leukemia patients (AML), generated in SFM and medium supplemented with autologous serum (AS). DCs were analyzed by phenotype characteristics, viability, and functionality. The results showed the possibility of generating viable DCs in all the conditions tested. In patients, the X-VIVO 15 medium was more efficient than the other media tested in the generation of DCs producing IL-12p70 (p=0.05). Moreover, the presence of AS led to a significant increase of IL-10 by DCs as compared with CellGro (p=0.05) and X-Vivo15 (p=0.05) media, both in patients and donors. We concluded that SFM was efficient in the production of DCs for immunotherapy in AML patients. However, the use of AS appears to interfere with the functional capacity of the generated DCs.