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Tuesday, April 27, 2004

Paper presentation went okay. Hurray! :-D

Saturday, April 24, 2004


Oh my goodness. Oh my goodness.
I **must** own this!!!
(Or at the very least just say the name a lot. iDuck... iDuck... iDuck...) :-D

A little more thinking aloud?

Well, this helped last time -- let's give it a shot. :-) Apologies for the length -- blog entries aren't exactly supposed to be mini-essays, but hey, I need to brainstorm!!

So I am, as regular readers know, attempting to write something about Congress and the debate over the unrelated business income tax in the mid-1980s. A quick summary: the Internal Revenue Code provides that charitable, educational, and many other types of nonprofit organizations are exempt from paying income taxes (I'll just refer to them as charities, for simplicity). There are lots of different rationales for this, but basically the idea is that the government should support the work that these groups do, and give them a subsidy in the form of a tax exemption. However, charities do have to pay taxes on their earnings from any business activities that aren't substantially related to their main purpose. So, for example, a private school doesn't pay taxes on the money it gets from tuition, becuase the purpose of the school is to educate students; but if the school rents out its athletic facilities to private groups for a profit, it will have to pay taxes on any money it earns from that. Deciding what counts as "substantially related" gets very tricky -- the classic case is that of the museum giftshop that sells posters and note cards bearing reproductions of artwork, then pays no taxes on the profits because these items are related to the museum's overall purpose of educating people about art. The tax that charities pay on this unrelated income is called UBIT (the unrelated business income tax).

Over the last 25 years or so, charities have been the victims of less funding and more demand for their services. As a result, they have been increasingly resorting to business-type activities to raise money. A lot of small businesses are not happy about this situation. Small business owners have approached politicians with countless stories about being forced into financial difficulties by competitors who have an unfair advantage. The charities, so the argument goes, are taking advantage of their special tax status to move into new industries, cut prices, and take business away from private companies.

There's just one problem with the unfair competition argument the small businesses are making -- legal and academic scholars have shown it to be false. The reasons are too complicated to get into here, but they fall into three major categories. First, there's nothing "unfair" about this competition -- the people profiting from businesses are private investors, while the people profiting from charities are people who need their services; the two can't be compared. Second, the tax advantage doesn't actually help that much because there are other features of charities that make it harder for them to get capital. Lastly, the UBIT doesn't help alleviate competition anyway -- it just makes things worse by forcing charities to concentrate in a few industries, thus having an even bigger impact on their competitors!

So basically, sometime in the 1980s the small business community gets really agitated, and Congress starts thinking about reforming the UBIT to tighten the rules on charities. There are thousands of pages of hearing transcripts, public comments, and testimony... the debate goes on for about five years... detailed proposals for change are considered... everyone is convinced that Congress will ring the death knell for charities... And then pffft. The Treasury Department says UBIT reform isn't a good idea after all, and that's the end of that.

So what happened? If everyone already knew that the UBIT was ineffective, how was the small business community able to raise such a ruckus? And what led to the collapse of the reform movement? Most importantly, what does this mean in terms of future UBIT reform?

The underlying problem with all of this is a tremendous degree of complexity. Very few people actually understand exactly how all the UBIT rules work, least of all the charities who are paying it. And nobody knows what the UBIT is really supposed to achieve, or what the best way is to achieve it. In short, there is no underlying conceptual framework -- if you don't know what you're trying to accomplish, it's very hard to come up with reform proposals that will satisfy everyone. This is a big idea (too big, too broad), but it comes out in a few particular tensions that characterized the debate:
1) Congress vs. Treasury. Congress wanted to make reform happen -- they wanted happy small businesses because happy business makes happy voters. Treasury wanted to do its job well -- in other words, to collect as much money as possible, while spending as little as possible. That means tighter rules that take more money from the taxpayers, but that aren't so complex to administer that the government has to expend lots of resources getting it right.
2) Small businesses vs. charities. Both of these were powerful interest groups with very sympathetic stories to tell. Congress could appease the small businesses only at the risk of alienating the charities and those who support them -- and who wants to be the one taking the money away from museums and hospitals? Similarly, the small businesses don't want to come across as the bad guys -- they want to keep their customers, not to run the charities into bankruptcy. So both Congress and small businesses had to frame the debate in terms of fairness -- it's not about favoring one group over the other, but about treating them both the same.
3) Slogans vs. science. The small business community (and Congress) got tremendous mileage out of repeating "unfair competition" over and over. After all, no one likes unfairness! And no one likes trying to figure out complex economic arguments about why unfair competition is a myth.
4) Policy vs. administration. A lot of the trouble with UBIT didn't have to do so much with unfairness in the rules as with injustice in how they were administered. Because the UBIT rules are so confusing, and because at least the smaller charities will generally not have a lot of experience with tax law, a lot of taxable income is simply misreported. And because the rules are conceptually vague, even if the IRS catches the error it will typically have a hard time deciding whether the income should really be taxed or not.

And the future of UBIT reform? Not sure yet. The issue is still very much out there, and unresolved. It seems like two ingredients are needed if UBIT is to be reformed: first, a few key people in the political process who will be as willing as the 1980s folks were to tackle the issue, and second, some kind of consensus about what the tax exemption for charities and the UBIT are supposed to achieve. That doesn't seem likely to emerge any time soon...

Wednesday, April 21, 2004

More fun with searches

And once again, some interesting searches led folks to this blog over the last couple of days. One was my first name (wow!); another was "arab fretwork" (pretty!). My personal favorite: "Does my P = your NP?" Oddly appropriate, though as far as I know there is no mention of computational complexity in here anywhere... :-)

Sunday, April 18, 2004

You are a GRAMMAR GOD!

If your mission in life is not already to
preserve the English tongue, it should be.
Congratulations and thank you!

How grammatically sound are you?
brought to you by Quizilla

Also -- oh! I found out today that Americans are the only ones who insist that commas and periods be enclosed within quotation marks at the end of a quote -- Brits and Canadians, wise logical folk, put the end punctuation inside only when it is part of the quotation. Otherwise it goes outside of the quotation marks. Hence -- I am currently reading an article entitled "Income Taxation of Legal Entities". Which makes much, much more sense!! (And yes, I know that my pickiness with regard to punctuation might ring a little hollow given that four of the five sentences in this paragraph begin impermissibly with conjunctions, exclamations, or a total absence of subject or verb. Call it poetic license.)

This from the girl who just spent half an hour literally in fits of giggles reading on-line posts about misused apostrophes... :-D

I'd call it meta but that would be passé...

The Times reviews the new novel by Vogue editor Plum Sykes, Bergdorf Blondes. And not so favorably. As P.C. noted, it's a little hard to tell which is more surreal, the novel or the review! Clearly the reviewer is less than impressed by Plum's plotting, moral sensibility, or respect for the intelligence of the reader, as evidenced by such scathing remarks as "the fascist force of the plotting insists that her narrator be strangely imbecilic" or "[t]he hideous conclusion is clearly telegraphed as the plot skids its way into the most insulting resolution imaginable." At the same time, she feels compelled to reference Truman Capote and Edith Wharton, as if there were any realistic probability of this being a comparable achievement. Ultimately the problem with both the review and the book, it seems, is that they aren't surreal enough -- Sykes treats her model-thin New York fashionista social set as if they were, and should be, our everyday reality; and reviewer Sicha seems to expect the book to be some kind of social commentary. Personally I think they're both taking the whole thing too seriously.

Saturday, April 17, 2004


As the use of on-line "social networks" has grown, so has the pressure on those who are on-line, but not necessarily terribly social, to join. No more. Enter the anti-social networks. From the relatively benign Introvertster to the rather more hostile Hatester, these new groups allow everyone, no matter how he/she rates on the shy-to-outgoing spectrum, to have a network of his/her very own. (In an interesting twist, one social network even has a community for antisocial people!) Now isn't that nice.

Fashion and law! I knew there was a paper topic in there...

Sunday, April 11, 2004

Who am I (supposed to be)?

Apparently even the Myers-Briggs test on can't tell what I'm supposed to be. Since its algorithm breaks ties at random, I am either:

Introverted (I) 62.5% Extroverted (E) 37.5%
Intuitive (N) 57.14% Sensing (S) 42.86%
Thinking (T) 50% Feeling (F) 50%
Judging (J) 55.26% Perceiving (P) 44.74%
Your type is: INTJ - "Mastermind". Introverted intellectual with a preference for finding certainty. A builder of systems and the applier of theoretical models. 2.1% of total population.

or (2)
Introverted (I) 62.5% Extroverted (E) 37.5%
Intuitive (N) 57.14% Sensing (S) 42.86%
Thinking (T) 50% Feeling (F) 50%
Judging (J) 55.26% Perceiving (P) 44.74%
Your type is: INFJ - "Author". Strong drive and enjoyment to help others. Complex personality. 1.5% of total population.

Either way, apparently I am a rare breed...

As for the Enneagram test:

Your conscious personality is Type 6w5. Professional specialists, 6w5s seek out career security and are more wary i personal relations. If you win their loyalty, they will never waver, They are both sceptical and likely to cling to some system or set of beliefs to keep anxiety at bay.
Your unconscious personality is Type 3w4. You are more led by your thoughts than your feelings. Anxious and introverted, you don't like to conform and have an inquisitive mind. You are also more close minded than average. If you like someone, you hide it.


Update: Okay one more and then I'm through procrastinating. This one is mean!
Sensate results were moderately low which suggests you are unaware, aloof, and disconnected from your environment and physical self.
Intellectual results were medium which suggests you are moderately internally motivated, self seeking, and independent.
Assertive results were moderately low which suggests you are timid, indirect, and unable to start and/or follow through on things.
Your consciously preferred type is Intellectual.

Saturday, April 10, 2004

Reign of Blue

Imagine gathering up every scrap, every picture you had that was associated with someone you once cared about, and giving it all up. Imagine having every memory you had of that person irretrievably erased. That's the premise behind Eternal Sunshine of the Spotless Mind [K.G. -- now there's a title!] This movie is just barely avoids crossing the line that divides clever movies from those so confusing that I dismiss them as unnecessarily frustrating -- it is not easy to figure out what's going on much of the time, what is real and what is in the main character's mind, but enough of it is decipherable on a first viewing to reassure me that there is actually a point to all the complexity. Despite the advertising campaign for the movie, which focused almost entirely on the fictional memory-erasure clinic, the broader implications of permitting selective deletion of memories are hardly dealt with; only in a secondary plot involving the procedure's inventor and an attractive young employee is there any suggestion of the serious confusion, imbalances of power, and potential abuses that might result. This is a love story, about two imperfect people and whether the sweet in their memories is worth the bitter. For someone as tied to memories as I am, there is nothing scarier than the thought of losing them permanently; after all, eventually even the sad ones take on a certain charm. (I find the idea of it almost unbearable, with the result that I was very sad in parts of the movie that were supposed to be not particularly affecting.) Halfway through having his memories wiped, the main character starts to realize the same thing. And the rest of the movie plays out like a high-speed chase, the patient's struggle to cling to his memories racing against a procedure that starts to feel inhuman. But really, the movie seems to suggest that the memories themselves aren't what's most important; it's our ability to learn from them, come to terms with painful things and grow. Memento-esque in its play with time, with some visual whimsy borrowed from Amelie and Jim Carrey trying to pull a Bill Murray in an uncharacteristically sedate role. Great, recommended, will make you wish you had blue hair too.

Friday, April 09, 2004

Wondrous Strange

At last -- yeah, I know it's been weeks. While I was gone, unfortunately, school and life kept on going, with the result that I'm now chasing it all with a one-week handicap (hence the delay in blogging). But definitely worth it.

So. I went to Japan with family over Spring Break and it was fabulous. I'd never been to Asia before at all but had been wanting to go to Tokyo ever since I saw Lost in Translation. All in all, I'd say it exceeded expectations -- beautiful and surprising and fascinating all at once. If you get a chance, go. :-)

Started out well with an amazingly comfortable flight considering it was 14 hours long... Absolutely breathtaking views of Alaska and especially Siberia (I flew over the Pole!) -- when mouuntains look enormous from the sky, I can only imagine what the view is like from the ground. Hmm. Perhaps next trip.

First stop: Tokyo. The people-watching is amazing -- so much creativity and risk-taking and individuality in the way people dress, especially those who are younger, student-aged. Jeans under handkerchief skirts, layered tops, legwarmers, brightly colored pointy-toed shoes; dyed hair everywhere. There's more homogeneity in businesspeople, who are uniformly in black or navy suits -- though one does spot the occasional businessman with punky blond hair. Just people-watching could take up days. There are older, quieter parts of the city too, with a very different feel and relatively free of tourists. But even in the ultra-crowded spots like Harajuku or Shibuya, it's amazing how quiet and respectful everyone is, as compared to other big cities like New York. Part of it is the relatively small number of cars, but there is a different attitude to walking around the city. You will very rarely see anyone talking on a cell phone (though everyone has them and checks text messages constantly). You will hardly ever be bumped or jostled.

This was the most striking thing to me -- how aware people are of those around them. People wear masks (kind of like those white surgeons' masks) in public when they have a cold (fascinating incentives problem -- the mask does no good to the person wearing it, and is probably actually rather uncomfortable; so how do they convince everyone to do it?) Sneezing and blowing your nose in public is considered very rude. In the subway, there are signs saying things like, "Be careful when you cross your legs -- it may inconvenience those around you" with a little drawing of a seated person accidentally kicking someone while leg-crossing. Even the tobacco industry has undertaken a hilarious ad campaign to teach people to smoke more considerately (the ads are online here; see also S.W.'s highly entertaining commentary). And everywhere, service is excellent and people are extremely polite. Not exactly warm and welcoming, but we did get stopped in the street a few times when we looked lost, by people offering to help. Could be a nice way to live, I think -- though it sometimes feels like there are a lot of rules and restrictions, there is also an overall sense of respect and awareness of one's effect on others.

And they just think of everything! Department stores have little plastic bags (and nifty dispensers!) at the entrance to cover your wet umbrella. When we walked into our hotel on a rainy day, they offered us hand towels to dry off with. That sort of thing. Little gadgets everywhere designed to remedy some inconvenience or minor embarrassment -- like the little speakers in ladies' restroom stalls that mimic a flushing sound so that you can disguise any noise, without wasting the water by actually flushing.

Next stop: Kyoto. It's a totally different world -- smaller and quieter, still a modern city but overall much more traditional. Temples and shrines are everywhere in the city, from little tiny ones to huge compounds. We were lucky enough to be there during some sort of illumination festival; at night the temples and surrounding streets were lit up, little windy pedestrian streets with lots of little shops and restaurants, crowds of people out at night. Also part of the festival was an exhibition of lanterns and flower arrangements designed by various artists. We didn't get to see the old imperial palace, and missed the really famous Zen rock garden because of rain the last day we were there, but did visit Kiyomizu-dera, without a doubt my favorite of the temples we saw. The buildings are set into a hillside with amazing views of the whole city. The main temple hall is much less ornate than is typical, just a plain wooden colonnade with hanging lanterns down the center and very little color -- and yet so powerful. The entire building rests on a huge wooden scaffolding structure perched on the side of the hill. And it's all equally beautiful when lit up at night. Osaka was next, a big city like Tokyo but without the funkiness, more business-like. Interestingly, a lot of the modern architecture was actually more impressive there than in Tokyo, perhaps because it's packed into a smaller space. Our hotel was near a famous arch-like building very reminiscent of La Defense in Paris, with a lovely traditional garden at the base complete with streams and fish and bridges. Note on the food: surprisingly, the food ranged from really really bad to ... pretty good. Only ate sushi once, at a non-fancy conveyor belt sushi place (much better than comparable places in the US!) Lots of tempura and soba. Many restaurants have "sets", with different little dishes, typically rice, a piece of fish, miso soup, tamago, a tempura shrimp, various pickled things, seaweed. The Japanese breakfast at hotels is the same kind of thing, soup, rice, fish, seaweed. The miso soup for breakfast is all warm and nourishing, definitely a habit I could pick up. But we had a few unpleasant surprises with vegetable pancakes and dessert-type things that *looked* yummy... So all in all, being a long-time fan of Japanese food of all sorts, I have to say I was a bit disappointed; the good meals were good, but I guess I expected a bit more uniformity in quality. Do love the vending machines everywhere though (yum, iced coffee). And the Tsujiki fish market in Tokyo is enough to make a seafood lover swoon.

So overall, fabulous and fascinating. And strange, and sometimes yummy, and very very fun. Japan trips highly recommended. :-)

Thursday, April 01, 2004

Stress level is high these last few days, what with trying to balance the competing demands of virtually nonexistent paper topics, reading for class, extracurriculars, and looking for an aparment in New York. Oh, and recovering from jet lag. Indeed -- this past February, after years of being a night owl and several months of sleeping 3am-10am, by sheer force of will I managed to convert myself into a student with semi-normal sleeping hours. It took some sleepless hours lying in the dark, many long late-night phone calls, and a trip to France, but somehow I pushed myself into midnight-8am. And a glorious transformation it was, while it lasted. So many daylight hours previously lost to me! So many places with yummy, uncrowded, early-morning breakfasts! Alas, all for nought. A week and a half after my Japan trip, I'm still wide awake until the wee hours of the morning. Sigh.

© Paula Levy
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