Canada and the United States—Trading Partners and Transfer Pricing Opponents?

Given the significant trading relationships between Canada and the United States, their transnational corporations and their tax authorities share more than a border. However, differences in transfer pricing regulations, tax rates, and regulatory enforcement philosophies have exacerbated many existing risks, and created new risks for executives in these corporations. These risks must be managed proactively, yet attempts at risk management are often incompatible with one tax authority or the other. Assuming that an operational transfer pricing framework is in place, there are several proactive strategies available to mitigate transfer pricing risk and potentially satisfy both tax authorities. An operational framework and proactive strategies, including documentation and advance pricing agreements, are discussed from the Canadian and US perspective, including expert interviews.     

Capacity Design of Coupled RC Walls

Capacity design aims to ensure controlled ductile response of structures when subjected to earthquakes. This article investigates the performance of existing capacity design equations for reinforced concrete coupled walls and then proposes a new simplified capacity design method based on state-of-the-art knowledge. The new method is verified through a case study in which a set of 15 coupled walls are subject to nonlinear time-history analyses. The article includes examination of the maximum shear force in individual walls in relation to the total maximum shear force in the coupled wall system, and subsequently provides recommendations for design.     

A TREASURE TROVE OF CHRONOLOGICAL LEARNING

The recent facsimile edition of Henricus Glareanus's Chronology of Livy, prepared by Anthony T. Grafton and Urs B. Leu, provides access to a primary source that is unique from the point of view of the history of science and scholarship and of the book and reading. The basis of the edition, a copy of Chronologia annotated by Glareanus's disciple Gabriel Hummelberg II, now preserved at the Princeton University Library, serves scholars both as a point of departure for outlining hypotheses on the teaching methods of early modern humanists as well as the role of chronology in the humanist curriculum. My reading of their edition is based on three points. First, I put the primary source of their choice in a context that includes provincial early modern educational centers as I believe that their enterprise could clear the way for future narratives on forgotten scholars who dealt with the issues of technical chronology. Second, I show the importance of Grafton and Leu's thesis on the procedures of transmission of teachers’ commentary, which, according to them, is documented by the Princeton copy of Chronologia. Third, I argue that the seemingly conservative decision to publish a paper edition of an annotated volume at the moment when state‐of‐the‐art digital tools for such editions are being tailored through the alliance of scholars and IT specialists should open a discussion among historians of the book and reading, science, and education that would lead to the determination of standards for scholarly editions of libri annotati.     

“FUTURE PAST”: TIME AND TELEOLOGY IN (ANCIENT) HISTORIOGRAPHY

The historian's account of the past is strongly shaped by the future of the events narrated. The telos, that is, the vantage point from which the past is envisaged, influences the selection of the material as well as its arrangement. Although the telos is past for historians and readers, it is future for historical agents. The term “future past,” coined by Reinhart Koselleck to highlight the fact that the future was seen differently before the Sattelzeit, also lends itself to capturing this asymmetry and elucidating its ramifications for the writing of history. The first part of the essay elaborates on the notion of “future past”: besides considering its significance and pitfalls, I offset it against the perspectivity of historical knowledge and the concept of narrative “closure” (I). Then the works of two ancient historians, Polybius and Sallust, serve as test cases that illustrate the intricacies of “future past.” Neither has received much credit for intellectual sophistication in scholarship, and yet the different narrative strategies Polybius and Sallust deploy reveal profound reflections on the temporal dynamics of writing history (II). Although the issue of “future past” is particularly pertinent to the strongly narrative historiography of antiquity, the controversy about the end of the Roman Republic demonstrates that it also applies to the works of modern historians (III). Finally, I will argue that “future past” alerts us to an aspect of how we relate to the past that is in danger of being obliterated in the current debate on “presence” and history. The past is present in customs, relics, and rituals, but the historiographical construction of the past is predicated on a complex hermeneutical operation that involves the choice of a telos. The concept of “future past” also differs from post‐structuralist theories through its emphasis on time. Retrospect calms the flow of time, but is unable to arrest it fully, as the openness of the past survives in the form of “future past” (IV).     

读路璜旱灾祈雨诗

古代科学技术落后,人们为祛除干旱常常采用礼神祈雨的办法。古代记述旱灾祈雨的诗歌存世不多,且篇幅较短;像路璜以五言操觚的长篇旱灾祈雨诗委属少见。该诗详细叙述地方与中央礼神祈雨的全过程,表达自己关注民生的情怀,留给后人无限遐思。雷公雨婆是不存在的,兴修水利才是抗击旱魃的最佳选择。人类构建"野花灿崖腰,苍苔没屐齿"的和谐社会任重而道远。     

GIS技术在萨拉乌苏考古遗址公园规划设计中的应用

传统规划设计工作的技术平台多以计算机辅助设计(CAD)为主,本工作以内蒙古自治区鄂尔多斯萨拉乌苏考古遗址公园规划为例,将Arc GIS Desktop作为技术平台应用到公园的规划设计工作中。首先,通过对规划区的实地踏勘,采集相关数据和资料,进行规划区数据库建设;其次,在数据库建设的基础上,通过GIS技术构建与现实环境对应的虚拟地理信息空间,实现规划区景观的三维可视化;最后,利用三维景观模型对现实地理环境进行模拟、分析及虚拟场景飞行。不同于传统CAD的二维工作平台,本工作借助GIS对空间数据和属性数据的强大处理功能及其三维景观可视化模块,为实现内蒙古鄂尔多斯萨拉乌苏考古遗址公园的科学规划提供辅助。     

中韩两国地方志中的本贯记录比较--以江西《吉安府志》和全罗道南原府《龙城续志》为中心

文章通过对中国江西省地方志《吉安府志》和韩国全罗道南原府地方志《龙城续志》中关于本贯记录的比较,说明"本贯"一词在古代中国社会和同时期的韩国社会具有不同的含义。本贯在古代中国社会表示"相应人物的本籍地",但是在同时期的韩国社会,则是指相应人物"远祖的本籍地",而相应人物的远祖是几百年以前或者一千多年以前存在的。而且,本贯在中韩两国的不同含义源于两国姓氏制度与本贯制度发展过程的差异。     

Des porte-parole protestants au chevet de l'édit de Nantes moribond

This article shows how the Edict of Nantes (1598), that had been criticized by French Protestants when it came out, progressively became the symbol of their belonging to the French nation and the acceptance of their religious particularity. But it is finally after its revocation (1685) that this Edict appears to make most sense to the Huguenot spokesmen. Thinking from a theological point of view as well as an historical, juridical and philosophical one, they consider it as a symbol of religious freedom. However, it is only by giving up their former status lost with the Revocation that they manage to develop an original thinking on the relationship between the State and individuals. In order to achieve this, they must distinguish between the subject or the citizen on one hand, and the believer on the other. But this distinction implies the renunciation of the nostalgia for aProtestant body, recognized as such in the kingdom of France.     

《贩书偶记》“子部·释家类·一切经音义二十六卷”条辨疑

通过辨析孙殿起所著<贩书偶记>"子部·释家类·一切经音义二十六卷"条,我们可为之增补两条新的版本信息1.该抄本为高邮王氏家传之书.2.该抄本的底本是最早不超过明英宗正统五年(1440)的永乐北藏本,或是更晚至顺治、康熙间刊刻的嘉兴藏本.     

Die Grippe‐Pandemie 1918–20 in der medizinischen Debatte

The Influenza Pandemic of 1918–20 in medical debate. The history of the so called Spanish Influenza 1918–1920 is summarized especially in regard to the developments in medical debate. In Germany, Richard Pfeiffer, who had discovered Haemophilus influenzae after the previous pandemic 1890 / 91, managed it to defend his thesis that his “bacillus” was the causative agent of the flu, by modifying his theory moderately. The Early Virology of influenza in postwar times was still fixed to bacteriology and did not yet have the force of school‐building. Aggressive therapy, e.g. with derivatives of chinine, were used in a concept of polypragmasy. The connection between influenza in animals and influenza in mankind was unknown or of no major interest till the rise of virology as an academic discipline in the 1950s. Since the outbreak of avian influenza in Asia 1997 virological archaeology is challenged to fill the historical part in the attempt to fight the threat of the highly pathogenic bird flu. In the beginning of the “short 20. century” politicians and doctors had no interest to build a “monument” of influenza. Today, virological reductionism does not have the power to (re‐)construct such a monument.