Discussion of Sections 338 and 338 Election of the Internal Revenue Research Proposal

Discussion of Sections 338 and 338 Election of the Internal Revenue Code - Research Proposal Example Under Section 338, if a purchasing corporation acquires 80 percent or more of the stock of the target corporation in a qualified stock purchase then the election in Section 338 may be done to treat the stock purchase as an asset purchase. This election must be not later than the fifteenth day of the ninth month, after the month in which the acquisition date occurs. If however the purchasing corporation decides not to or fails to make such an election, then it will be a carryover basis in the target’s assets. Such an election in Section 338 will benefit or have an economic value to the purchasing corporation only â€Å"if the present value of future tax savings resulting from the ‘step-up’ in basis of the target's assets exceeds the current tax cost of such a step-up†. As explained by Silverman, in order to achieve this basis step-up, the target corporation must recognize the full gain or loss inherent in its assets.

Morphology :: MOO Teaching Technology Education Essays

Morphology "Everything we experience today in the mode of a limit, or as foreign, or as intolerable will have returned to the serenity of the positive. And whatever currently designates this exteriority to us may well one day designate us. Only the enigma of this exteriority will remain" --- Michel Foucault If the architecture of MOOs replicates real-life places like classrooms, we can be assured that real-life problems exist there, too. Educators need to be aware of how and in what forms these problems take shape online, in addition to knowing how to handle them. It is not easy to find answers in the mountains of popular culture hype and mass media reports on the Internet. Depending on what magazines and newspapers you read, Internet technology is either the salvation or the demise of civilization. Certainly the rapid growth of access to the Internet has parents and educators wringing their hands over how to protect children and students online from some of the same dangers they face in the physical world. Yet one of the most encouraging aspects of the growth and scope of the Internet is the opportunity for all of us to contribute to the social construction of ethical guidelines in the development and use of Internet-based technologies in educational settings. There is a fine line between giving students the latitude to be creative online and setting them loose with no ethical boundaries whatsoever. Just as in traditional classroom settings, common sense and proper preparation go a long way toward anticipating problems and resolving them. It is not necessary to blame the whole of cyberspace and thereby throw the virtual baby out with the virtual bathwater. There are ways to manage the "fluidity" associated with identity, speed, and open access on the Internet. We need to avoid the rhetoric of negative cyber-hyper and engage instead in productive discussion about the Internet in terms of its positive impact on individual and collective lives. Especially with respect to the use of Internet technology in education, we should do so rhetorically, going slowly, doing our homework, so to speak, before we make claims about the dangers of the Internet. Secondly, and perhaps less metaphorically, real-time teaching also creates real-time homework for teachers. The MOO will change the way you relate to your students, and teachers may find that they must give up their 'principle orientation' toward the individual student (Porter). Teletechnology mixes new modes of intelligibility (and new codes of behavior) with new pedagogical contracts between teacher and student, and it also effectively 'outs' the faculty in ways that they may find unnerving.

Gender Dysphoria and the Persecution of Transgender People

The morality of sex has been given wide attention because it is a principle to differentiate between proper sexual behavior and improper sexual behaviour. Since the sexual act is connected with the giving birth to children (human reproduction),it despite being a very private and intimate matter. People normally born with only one sex either male or female. There are people who unsatisfied with their own sex which most probably happen in man,they undergo gender reassignment therapy to make themselves a real woman.In 20th century, issue regarding sex exchange is still a rare and unprecedented case. Einar Mogens Wegener make an outstanding decision that he want to undergoes sex exchange,he is one of the first identifiable recipients of male to female sex reassignment therapy which after that named himself as Lili Elbe. In 1930,the medical technology is still not advanced enough to make sure the sex exchange operation can be successfully done but he still determined with his own decision .He went through a series of five operations over a period of two years. However, three months after her last operation, he died. His cause of death is believed to have transplant rejection. He is a pioneer to the history of sex exchange. In the aspect of psychology,the cause of human being who unsatisfied with their own sex and strong willing to undergo sex exchange is due to ‘gender dysphoria’ but the cause of gender dysphoria is still an unknown.Recently, scientific evidence suggests that there are biological influences before birth. This imply that gender identity, along with other physical characteristics, is established long before environmental factors influence individual socialisation. A recent experiment suggests that both biology and some environment influences may play a role in determining gender identity. In the medical model, transsexual men and women are diagnosed with gender dysphoria and gender identity disorder.In the DSM IV the American Psychiatric A ssociation presents several components of what it calls ‘gender identity disorder’: * a strong and persistent cross-gender identification, which is the desire to be, or the insistence that one is, of the other sex * not merely a desire for any perceived cultural advantages of being the other sex but evidence of a persistent discomfort about one’s biologically assigned sex * clinically significant distress or impairment in social, occupational or other important areas of functioning. While some forms of gender identity dysphoria may be temporary and thus ranssexualism is immutable. However, the costs of sex reassignment surgery vary. According to the data collected through internet,Female to male surgery in Toronto costs approximately $10,000 to $12,000. In the UK, where the Gender Identity clinic of the Clark Institute of Psychiatry used to sent its clients, male to female surgery costs approximately ? 9,000 (approximately $18,000 Canadian). The information that is available on costs of sex reassignment surgery indicates that in the United States male to female surgery can cost between $10,000 and $28,000 (U.S. ). According to the 1996 British Columbia law reform project on human rights and the transgendered community, male to female sex reassignment surgery ranges from between $5,000 and $10,000. Female to male sex reassignment surgery costs considerably more, ranging from $20,000 to more than $60,000. Under legal and medical issues,the authors note that the legal system and the medical system have engaged in the ‘medicalisation of identity’. For example, the courts ask whether, medically speaking, a person is a woman or a man.In Ontario, the government interpretation of the Vital Statistics Act requires a medical letter and sex reassignment surgery before allowing a change in the birth certificate. Government policies for other documentation vary, but many ask for medical proof that the individual is transsexual instead of ac cept self-identification. Consultees reported instances of court cases such as custody disputes where the transsexual parent was required to undergo medical assessment to confirm the person's gender identity.Next,transgendered person must receive legal recognition from a gender identity clinic, which is not always accessible, in order to receive appropriate service or treatment from the health care system and other organizations that they may come in contact with. General practitioners often do not have suffivcient resources or expertise that provide appropriate services to transgendered patients. As a result, there are many transgendered individuals who self-medicate and self-treat with hormone therapy, which subsequently puts their health at risk.Many individuals in this situation reported that they felt they have no other option due to expensive operation cost and lack of expertise in this aspect. There are some case that a pre-operative transsexual woman and one intersexed woman should always bring along the letters written by their doctors because the letter recommend the individual and advised that the individual had been diagnosed as having ‘gender identity disorder’ so that the people address the individual as a woman.These two individuals indicated that they carried this letter at all times in the event that they were stopped by the police, stopped when using women’s change rooms or washroom facilities, questioned at government agencies or in any other official setting. It is a recent trend that a growing number of people who are transgendered no longer consider sex reassignment surgery as a suitable option for them either due to cost, medical risks, medical barriers or even on principle.Many of them do not wish to assimilate into a society with rigid bifurcated standards of sex and gender congruence, but rather ask that society accepts and adapts to transgendered people. Nevertheless, a large number of transsexuals in Ontario seek sex reassignment surgery but due to a recent change in government policy, economic and medical barriers, they cannot access it. These factors also effectively preclude transgendered people from accessing hormone therapy.Sex change is a term often used for sex change in humans, that is all medical procedures transgender people may pursue, or specifically to sex reassignment surgery, which usually refers to genital surgery only. It is also sometimes used for the medical procedures intersex people undergo or more often are subjected to as children. â€Å"Sex change† is sometimes also used for the whole process of changing gender role and the medical procedures associated with it.Actually,to them, changing of gender role such as living as a woman instead of living as a man, or living as a man instead of living as a woman, is much more important than any medical procedures. There are many different opinion of people nowadays toward the transgender issue. Some people thought that people who really decide to change their gender must be a brave and ambitious people. They give people some positive effect that we must not let our fear to outweigh our desire to make our dreams come true.Thus,they feel that people who undergoes transgender without care on other people’s view is so courageous as the ready to suffer of the pain in operation and in the cold-shoulder of society. However,there are some people who think that people who not appreciate just will unsatisfired with their own gender,we should appreciate what we had as a gift of God. Therefore,there are some family members who not agree with them and feel that it is a shame toward the reputation of a amily thus this causes some of the thransgender persons homeless. This is because transsexual youth who are open about their identity face extreme abuse and rejection from families and peers. Many are forced to leave their home communities and survive on the streets. During the consultation, some individua ls indicated that they were not in conflict with the diagnosis of gender dysphoria. Indeed, the diagnosis facilitated their ability to identify in their felt gender and allowed them to access sex reassignment surgery.One group involved with transgendered individuals who are homeless, street workers or living with HIV/AIDS stated that the medical diagnosis is especially important for lower income transsexuals who cannot afford private medical care or who are employed during the transition from the birth assigned sex to their felt gender. Others were, at the very least, concerned with the negative stereotyping attached to a diagnosis of a psychiatric disability. Most community members stated that access to medical services for sex reassignment should not be barred even if the psychiatric diagnosis is removed.One group made an analogy between the accommodation of medical needs related to aligning one’s physical appearance to one's gender identity on the one hand and the medical care that is required during pregnancy on the other. For instane,The Supreme Court of Canada in Brooks recognized pregnancy as a health issue rather than a disability and required that accommodation be provided on the former basis. Similarly, it is argued that transgendered persons should be able to obtain accommodation without being ‘pigeon-holed’ as persons with disabilities. According to the data,transgender person actually face a lot of morality problems.For example the transgender students face severe discrimination and harassment in schools. 89. 5% of transgender students report feeling unsafe in schools. Transgender students are at higher risk of dropping out of school and of suicide. Next, many transgender and gender non-conforming students have no access to bathrooms. Some are told to use the bathroom that does not correspond to their gender identity. Many are expelled from school because the school does not know where the person should use the bathrooms. Then, more than one quarter of them said they had lost a job due to being transgender or gender non-conforming and half were harassed.Many Americans have a profound lack of understanding of what it means to be transgender. Consequently, transgender people commonly face a wide variety of discriminatory barriers to full equality. They sometimes face difficulties meeting their basic needs such as getting a job, housing and health care or in having their gender identity respected too like in the simple act of going to a public restroom. As a conclude,the transgendered community has to deal with discrimination, physical violence and undue stereotypes in reality. Those are eight main problems face by transgender people: (a) HIV/AIDSHIV/AIDS is a significant health consideration for transgendered individuals who engage in high-risk behaviors such as unprotected sexual activity or intravenous drug use. This issue is highlighted by a research report done in Vancouver, which indicated that 70 to 8 0 per cent of transgendered sex trade workers are HIV positive. (b) Transgendered Youth Transgendered youth have limited access to professionals who understand the nature of gender identity and how to support a transgendered individual. Continued homophobia and transphobia in the social services directed to gay, lesbian and bisexual and transgendered youth compound this.This was stated several times in the consultations. One woman related the story of her incarceration in youth group homes before her sex reassignment surgery. She was told to act like a man, disciplined for not doing so, and survived the process simply by denying her transgendered status. Further, consultees stated that the educational system does not understand transgendered issues. Transgendered youth and transgendered parents both face barriers dealing with the school system. Some social service agencies are beginning to recognize the need to address these issues.For example, the Catholic Children’s Aid of Metropolitan Toronto has developed a policy that includes transgendered youth in its intervention policy. The policy states that all staff care providers and volunteers must undergo training with regard to the needs, concerns, language, symbols and culture of gay, lesbian, bisexual and transgendered youth and families. Issues concerning sexuality that arise in service delivery to transgendered youth should be treated with the same respect, concern, sensitivity, and confidentiality accorded to heterosexual youth and families. c) Services and Media Service delivery to the transgendered community is generally reported to be poor. In consultations, individuals reported that they had been stopped by the police and told to identify who they were. Hospital workers show prejudicial attitudes in treatment once the birth assigned sex of the individual is discovered. Insurance companies give differential treatment once the transsexual identity of an individual is discovered. Transgendered wome n have difficulty accessing women’s shelters and other social service agencies.Families of transgendered people, including spouses, children and parents also lack the resources to obtain the support and understanding they need and to be free from discrimination. The media generally shows a misunderstanding of the issues faced by transsexuals. There is often confusion of terminology used to describe individuals, i. e. not distinguishing between the issues of transsexuals, cross-dressers, etc. The result is that derogatory or sensationalistic language is frequently used when reporting on issues that are related, in whole or part, to transgender issues. d) OHIP Coverage From 1970 to 1998, OHIP coverage had been provided for sex reassignment surgery for individuals approved by the Clarke Institute of Psychiatry. Ontario’s Ministry of Health treated most aspects of sex reassignment surgery, including out-of-province procedures, as reimbursable services under OHIP. Section 7 of the Health Insurance Act] outlines that breast enlargement, augmentation, mammoplasty or breast reconstruction in a male to female conversion is not an insured benefit unless prior authorisation is received from the Ministry of Health.In all cases, health coverage for sex reassignment surgery in Ontario was contingent upon having completed the program at the Gender Identity Clinic at the Clarke Institute of Psychiatry and having been recommended by the Clinic for sex reassignment surgery. In October 1998, the Ontario government decided to remove sex reassignment surgery from the list of services covered by provincial health insurance. This decision was met with public outcry from the transgender community and is interpreted as a statement that the government does not consider the issues of transgendered people as valid, significant, or important.This decision has a profound impact on transgendered people who are part of a highly marginalised community and who are also often in a lower income bracket which means they lack the financial resources to pay for surgery. The Ministry of Health has not provided any rationale behind the decision to delete health insurance coverage for sex reassignment surgery. An article in the Toronto Sun, based on information apparently provided by the government, states that the savings will be applied to cardiac surgery.However, the public funds allocated for sex reassignment surgery are insignificant when compared to the budget of the Ministry of Health. The article ignores the fact that qualified professionals have identified surgery to be a medical necessity. Moreover, the consequences of not covering surgery may include additional or increased costs in other areas such as counselling and health care. It may also result in an elevated risk of suicide in the transgendered community because individuals are unable to obtain appropriate services. e) Fear of discovery Transsexuals and transgenderists fear discovery of their birth -assigned sex. Likewise, for cross-dressers, the fear of being discovered is a significant concern. The repercussions of being discovered can include termination of employment, loss of housing, loss of services, social isolation and other forms of discrimination, harassment and possibly violence. (f) Hate Crimes and Transgendered Individuals Crime statistics indicate that transgendered people are victims of hate crimes that may also involve violence.Furthermore, such crimes may not be taken as seriously or dealt with appropriately. As noted in a draft brief by the Canadian Task Force for Transgendered Law Reform: (g) Poverty There is no statistical data about the rates of poverty for transgendered people. However, it was noted during consultation that transgendered persons experience severe economic hardship. This could be due to the difficulties in accessing medical and insurance services, discrimination in the workplace, and social and economic marginalisation.Mirha-Soleil Ross, t he co-ordinator of ‘Meal Trans’ a program for transgendered people in Toronto, states that 90% of those people who utilise the program earn less than $10,000 a year. (h) International Persecution of Transgendered People The social rejection of transgendered persons manifests itself internationally through cross-border issues of recognition of transgendered individuals as refugees and related issues of returning them to their country of origin under international law. For example, a transgendered woman who claimed refugee status in Canada was deported to Mexico although she alleged fear of persecution if returned.Public and government should give more concern toward transgender people,we must not discriminate those people but give more positive support toward them as it is not easy fot a person to decide to undergo sex exchange,the person must be tough and brave enough. In order to minimize the rate of suicide in the population of transgender people,we should pay more at tention to them and thus give them an equal rights as what normal people got. We should not evade them in public but on the other hand we should respect their choice of undergo transgender.We always erroneously believe that transgender normally is AIDS carrier but in fact they too love themselves and of course will protect themselves for AIDS by having proper sex intercourse. Recent studies have shown that transgender people are at high risk for HIV. Few studies, however, have directly compared the HIV risks and sexual health of transgender persons with that of other sexual minority populations. This study used baseline data of intervention studies targeting transgender persons, men who have sex with men, and women who have sex with women and men to compare their HIV risk behavior and sexual health.No significant differences were found between transgender persons and non-transgender men or women in consistent condom use or attitudes toward condom use. Transgender persons were less l ikely to have multiple partners and more likely to be monogamous than men who have sex with men; no differences were found between transgender persons and the women in this respect. When combining data on condom use, monogamy, and multiple partners, transgender persons did not differ from either non-transgender group in their overall risk for HIV.Transgender persons were less likely than the men or the women to have been tested for HIV. With regard to HIV prevalence, 17% of the men compared to only one transgender person and none of the women reported being HIV-positive. Transgender persons were also less likely than men who have sex with men to use drugs; no differences were found in the use of alcohol. However, with regard to mental health, transgender persons were more likely than the men to have experienced depression and more likely than men or women to have considered or attempted suicide.Finally, transgender persons reported the lowest levels of support from family and peers. Thus, in our sample, transgender persons appear to be at lower risk for HIV but at higher risk for mental health concerns than men who have sex with men. Remarkably few differences were found between transgender persons and women who have sex with women and men-a finding which might reflect the impact of social stigma on sexual health and have implications for the design of future HIV/STI prevention efforts.

What Is a Chemical Element Definition and Examples

An element or chemical element is the simplest form of matter in that it cannot be further broken down using any chemical means. Elements are made up of smaller particles, but you cant take an atom of an element and perform any chemical reaction that will break it apart or join its subunits to make a bigger atom of that element. Atoms of elements may be broken down or fused together using nuclear reactions. Element Basics So far, 118 chemical elements have been found. Of these, 94 are known to occur in nature, while the others are manmade or synthetic elements. Eighty elements have stable isotopes, while 38 are purely radioactive. The most abundant element in the universe is hydrogen: In the Earth (as a whole), its iron. In the Earths crust and the human body, the most abundant element by mass is oxygen. The term element may be used to describe atoms with a given number of protons or any amount of a pure substance made up of atoms of one element. It doesnt matter whether the number of electrons or neutrons varies throughout the sample. What Makes Elements Different From Each Other? How can you tell if two chemicals are the same element? Sometimes examples of a pure element look very different from each other. For example, diamond and graphite (pencil lead) are both examples of the element carbon. You wouldnt know it based on appearance or properties. However, atoms of diamond and graphite each share the same number of protons. The number of protons, particles in an atoms nucleus, determines the element. Elements on the periodic table are arranged in order of increasing numbers of protons. The number of protons is also known as an elements atomic number, which is indicated by the number Z. The reason different forms of an element (called allotropes) can have different properties even though they have the same number of protons is that the atoms are arranged or stacked differently. Think of it in terms of a set of blocks. If you stack the same blocks in different ways, you get different objects. Examples of Elements Pure elements can be found as atoms, molecules, ions, and isotopes. Examples of elements include a hydrogen atom (H), hydrogen gas (H2), the hydrogen ion H, and isotopes of hydrogen (protium, deuterium, and tritium). The element with one proton is hydrogen. Helium contains two protons and is the second element. Lithium has three protons and is the third element, and so on. Hydrogen has the smallest atomic number (1), while the largest known atomic number is that of the recently discovered element oganesson (118). Pure elements contain atoms that all have the same number of protons. If the number of protons of the atoms in a sample is mixed, you have a mixture, called a compound. Examples of pure substances that are not elements include water (H2O), carbon dioxide (CO2) and salt (NaCl). Note how the chemical composition of these materials includes more than one type of atom. If the atoms had been the same type, the substance would have been an element even though it contained multiple atoms. Oxygen gas (O2) and nitrogen gas (N2) are examples of elements. What Is a Chemical Element Definition and Examples A chemical element, or an element, is defined as a material which cannot be broken down or changed into another substance using chemical means. Elements may be thought of as the basic chemical building blocks of matter. There are 118  known elements. Each element is identified according to the number of protons it has in its atomic nucleus. A  new element may be created by adding more protons to an atom. Atoms of the same element have the same atomic number or Z. Key Takeaways: Chemical Element A chemical element is a substance consisting of only one type of atom. In other words, all atoms in an element contain the same number of protons.The identity of a chemical element cannot be changed by any chemical reaction. However, a nuclear reaction can transmute one element into another one.Elements are considered to be the building blocks of matter. This is true, but its worth noting atoms of an element consist of subatomic particles.There are 118 known elements. New elements may yet be synthesized. Element Names and Symbols Each element may be represented by its atomic number or by its element name or symbol. The element symbol is a one or two letter abbreviation. The first letter of an element symbol is always capitalized. A second letter, if it exists, is written in lower case. The International Union of Pure and Applied Chemistry (IUPAC) has agreed on a set of names and symbols for the elements, which are used in scientific literature. However, the names and symbols for the elements may be different in common use in various countries. For example, element 56 is called barium with element symbol Ba by the IUPAC and in English. It is called bario in Italian and baryum in French. Element atomic number 4 is boron to the IUPAC, but boro in Italian, Portuguese, and Spanish, Bor in German, and bore in French. Common element symbols are used by countries with similar alphabets. Element Abundance Of the 118 known elements, 94 are known to occur naturally on Earth. The others are called synthetic elements. The number of neutrons in an element determines its isotope. 80 elements have at least one stable isotope. Thirty-eight  consist solely of radioactive isotopes which decay over time into other elements, which may be either radioactive or stable. On Earth, the most abundant element in the crust is oxygen, while the most abundant element in the entire planet is believed to be iron. In contrast, the most abundant element in the universe is hydrogen, followed by helium. Element Synthesis Atoms of an element may be produced by the processes of fusion, fission, and radioactive decay. All of these are nuclear processes, which means they involve the protons and neutrons in the nucleus of an atom. In contrast, chemical processes (reactions) involve electrons and not nuclei. In fusion, two atomic nuclei fuse to form a heavier element. In fission, heavy atomic nuclei split to form one or more lighter ones. Radioactive decay can produce different isotopes of the same element or a lighter element. When the term chemical element is used, it can refer to a single atom of that atom or to any pure substance consisting only of that type of iron. For example, an iron atom and a bar of iron are both elements of the chemical element. Examples of Elements Element are found on the periodic table. Matter consisting of a single element contains atoms that all have the same number of protons. The number of neutrons and electrons does not impact the identity of an element, so if you had a sample containing protium, deuterium, and tritium (the three isotopes of hydrogen), it would still be a pure element. HydrogenGoldSulfurOxygenUraniumIronArgonAmericiumTritium (an isotope of hydrogen) Examples of Substances That Are Not Elements Substances that are not elements consist of atoms with different numbers of protons. For example, water contains both hydrogen and oxygen atoms. BrassWaterAirPlasticFireSandCarWindowSteel What Makes Elements Different From Each Other? How can you tell if two  chemicals  are the same element? Sometimes examples of a pure element look very different from each other. For example, diamond and graphite (pencil lead) are both examples of the element carbon. You wouldnt know it based on appearance or properties. However, atoms of diamond and graphite each share the same number of protons. The number of protons, particles in an atoms nucleus, determines the element. Elements on the  periodic table  are arranged in order of increasing numbers of protons. The number of protons is also known as an elements atomic number, which is indicated by the number Z. The reason different forms of an element (called allotropes) can have different properties even though they have the same number of protons is that the atoms are arranged or stacked differently. Think of it in terms of a set of blocks. If you stack the same blocks in different ways, you get different objects. Sources E. M. Burbidge; G. R. Burbidge; W. A. Fowler; F. Hoyle (1957). Synthesis of the Elements in Stars. Reviews of Modern Physics. 29 (4): 547–650. doi:10.1103/RevModPhys.29.547Earnshaw, A.; Greenwood, N. (1997). Chemistry of the Elements (2nd ed.). Butterworth-Heinemann.