Transatlantic Competition Research Articles

Containing Technology and Allies Alike: The Cold War, Intra-NATO Relations, and the U.S. Centrifuge Classification Initiative, 1958–1962

Abstract This article discusses how West European governments reacted to U.S. efforts to control the emergence and spread of gaseous diffusion and ultracentrifuge technology for uranium enrichment. The article focuses on Dutch, British, and West German Cold War perspectives on nuclear technological cooperation with the United States. U.S. insistence on maintaining secrecy around the ultracentrifuge was driven not only by technological and nuclear nonproliferation concerns but also by overarching Cold War dynamics at the time of the 1961 Berlin crisis and NATO's nuclear modernization. The Dutch–West German exploration of bilateral nuclear cooperation on gas centrifuges and the subsequent U.S. classification efforts also reveal a story of transatlantic competition over technological ambitions, commercial interests, and Western Europe's strategic potential. The article thus highlights the intersection of the history of science and technology and Cold War diplomatic and nuclear history, combining fresh material from Dutch archives with U.S. and British primary sources.

Data, Innovation and Transatlantic Competition in Finance: The Case of the Access to Account Rule

Technological innovation is transforming the structure of the retail banking sector. Traditional business models are facing a rapid disruption process led by the emergence of FinTech companies which provide innovative digitally-enabled banking and financial services. In order to offer payment initiation services and account information services, third party providers need to access customer accounts, since information on the availability of funds on the consumer’s payment account is a key element. The paper focuses on two major trends that underpin this new business environment, which is known as Open Banking. First, the EU has taken the lead in the transition by providing, within the revised Payment Service Directive (PSD2), a sector-specific portability regime (the access to account rule) expressly aimed at fostering competition. Indeed, one of the key points of the PSD2 is that new market players should be granted access to account data. Second, in such a context standardization plays a crucial role with regards to the implementation process and the overall effectiveness of this new pro-competitive mechanism. Regulators in other countries have recently expressed interest in developing frameworks that put consumers in control of their account data. Additionally, they have encouraged standardization initiatives aimed at defining shared, open application programming interfaces (APIs). Will regulators in the U.S. follow suit?

Foreign Investment in Iran: Multinational Firms’ Compliance with U.S. Sanctions

When President Donald Trump withdrew from the nuclear deal with Iran, he ushered in a high-stakes competition between the United States and Europe to determine whether unilateral U.S. sanctions could impose overwhelming pressure on Iran, or if European governments could protect the economic gains that accrued to Tehran from the nuclear deal. If European countermeasures defused American sanctions, the incentives for Iran to abide by the deal would remain intact. Perhaps more importantly, Europe would demonstrate that Washington cannot wage economic warfare without its consent and participation. A critical measure of European ability to restrain the United States is the response of European multinational corporations to the return of U.S. sanctions. In addition, it is important to monitor how top Asian multinationals navigate the transatlantic competition. Will leading multinationals withdraw from the Iranian market rather than risk losing access to American markets and the U.S. financial system? Or will firms conclude the U.S. threats are hollow, since punishing European and Asian multinationals would inflict substantial damage on American firms and consumers? This report serves as a scorecard for all those who are tracking sanctions compliance, including the Department of the Treasury, Department of State, and U.S. officials in other government agencies who monitor sanctions compliance. It provides a country-by-country list of firms with investments in Iran, indicating which ones are likely to stay, which to leave, and which have made no announcement. In all, the report covers 232 companies and business associations, of which 67 are part of the Fortune Global 500 list of firms with the highest revenues. In the four months since the U.S. withdrawal from the 2015 nuclear deal, 31 European and Asian firms in the Global 500 announced they would be leaving the Iranian market or hinted their exit was imminent. The list includes France’s Total, Airbus, and PSA/Peugeot; Denmark’s Maersk, Germany’s Allianz, and Siemens; Italy’s Eni; Japan’s Mazda and Mitsubishi UFJ Financial Group; and the UK’s BP. In contrast, Renault is the only European member of the Global 500 that expressed an intention to resist American pressure, yet its COO indicated in July that the company will suspend operations. Since U.S. sanctions do not apply in general to food and medicine, Nestle has announced it will continue operations in Iran. France’s Sanofi, Germany’s Bayer, and Switzerland’s Roche have not yet announced their plans, yet sanctions may not affect their pharmaceutical work, nor Danone’s beverage business. Lufthansa will also continue its flights to Iran, which do not necessarily conflict with sanctions. All together, we assess that 71 companies plan to withdraw from Iran, 19 plan to stay, and 142 have either not decided or not broadcast their decision.

BEPS, ATAP and the New Tax Dialogue: A Transatlantic Competition?

The Tax Cuts and Jobs Act (TRA17) signed into law by President Trump on 22 December 2017 contains multiple provisions that incorporate the principles of the OECD/G20 Base Erosion and Profit Shifting (BEPS) into domestic US tax law. Together with the changes in the 2016 US Model Tax Treaty, these provisions mean that the United States is following the European Union in implementing BEPS and particularly its underlying principle, the single tax principle (all income should be subject to tax once at the rate derived from the benefits principle, i.e. active income at a minimum source tax rate and passive at the residence state rate). This represents a triumph for the G20/OECD and is incongruent with the generally held view that the United States will never adopt BEPS.

Is Full Transatlantic Competition Law Convergence Realistic, or Even Desirable?

Commentators tend to assume that competition law convergence between the United States and the European Union is both attainable and desirable. This article explores whether that assumption is valid, and what it would entail. The conclusion is that in some areas competition law reflects deeper social differences between societies and that competition law convergence is not only unrealistic, it may even be undesirable.

Globalization or Regionalization of the Defense Industry in the European Union

The defense industry is unlike other industries due to the nature of its products and given the significance of the defense industry for national security. Since the end of the Cold War, the European defense industry has undergone a huge transformation. Decline in demand for military equipment and growing research and development costs for major weapons systems have strengthened economic pressure to concentrate arms-production activities in Europe. Co-operation in the European defense industry sector has taken different forms, shapes and magnitudes. Reconstruction of the European defense industry through mergers, acquisitions and joint-ventures is being shaped by strong market. There is a growing tendency towards greater co-operation and collaboration at the European level (regionalization) in order to create a competitive European defense industry, capable to compete, cooperate and integrate on equal terms with stronger and more productive American arms-producing companies. A combination of liberalism and mercantilism focuses on competition and the need to maintain considerable European capacity and autonomy in the field of armaments production. Such a balance would not only encourage a greater degree of transatlantic competition but also transatlantic co-operation.

Adopted EU Directive on Takeover Bids – The Target Company Management’s Position, Defensive Measures and Insider Dealing

The defense industry is unlike other industries due to the nature of its products and given the significance of the defense industry for national security. Since the end of the Cold War, the European defense industry has undergone a huge transformation. Decline in demand for military equipment and growing research and development costs for major weapons systems have strengthened economic pressure to concentrate arms-production activities in Europe. Co-operation in the European defense industry sector has taken different forms, shapes and magnitudes. Reconstruction of the European defense industry through mergers, acquisitions and joint-ventures is being shaped by strong market. There is a growing tendency towards greater co-operation and collaboration at the European level (regionalization) in order to create a competitive European defense industry, capable to compete, cooperate and integrate on equal terms with stronger and more productive American arms-producing companies. A combination of liberalism and mercantilism focuses on competition and the need to maintain considerable European capacity and autonomy in the field of armaments production. Such a balance would not only encourage a greater degree of transatlantic competition but also transatlantic co-operation.

Transatlantic Answers to the Challenge of Orphan Books: Google’s Books Settlement and Its European Counterpart

A great leap in creating a digital library for the internet world is Google’s Books Search initiative. In a pragmatic approach of' ‘do first and then ask' Google started digitizing library collections from around the word. More recently Google and its partners have settled an agreement that put an end to class actions introduced by copyrights holders. One of the most interesting parts in the settlement relates to orphan books, books whose copyright status is uncertain. According to the agreement Google would be able, under certain conditions, to digitize and distribute these books electronically. It might have been one of most important breakthroughs in copyright, based on the 'opt out' option for copyright owners. However the agreement was rejected in some important parts (the ‘opt-out’ clause included) by a US Federal judge. The fact that Google began scanning 'out-of-print' books created an awareness of importance of the issue in Europe. There were no class actions available in European countries on copyright issues. The only remedy might have been a top-down approach based on legislation – as extension of collective licenses used in Denmark, Finland, Sweden, Norway or Iceland. Most recently the French Senate began to discuss a bill aimed to build a framework for digital utilization with an 'opt-out' mechanism similar to the one envisioned in Google’s agreement. The initial steps seemed to favor the US. That created in Europe an incentive to establish similar solutions for orphan books through statute law. The recent rejection of Google's agreement and its highly uncertain future might restart, once again, a transatlantic competition.

EU–U.S. Military Relations and the Question of the Transnational Capitalist Class

This research note examines whether the status of EU–U.S. military relations confirms the increasingly popular notion of a transnational capitalist class, integrated on a global scale and accompanied by the cessation of interimperialist rivalry. It focuses on two cases: formation of the European Security and Defense Policy and the setting-up of an EU armaments policy as well as the respective transatlantic struggles over the nature of these two policies. It concludes by highlighting empirical inconsistencies in the transnationalist argument, as demonstrated by the continuation of transatlantic competition over the formation of a separate EU military-industrial identity. Instead of the formation of a global capitalist class, current developments in EU–U.S. military relations point to a territorially bounded capitalist internationalization. Heralded as a new leap in Marxist theory, transnationalism is in fact a dead end, to the extent that it is unable to interpret a new wave of political, economic, and strategic competition among the great capitalist metropolises of our time.

Fructose 2,6-bisphosphate: the last milestone of the 20th century in metabolic control?

ery Hers reported the discovery of fructose 2,6-bisphosphate, a novel, potent allosteric stimulator of liver 6-phosphofructo-1-kinase. The Brussels team were also at the forefront of other advances in hepatic glucose metabolism and many of their findings were published in the Biochemical Journal. Their demonstration that the concentration of fructose 2,6-bisphosphate was greatly increased in hepatocytes incubated in the presence of glucose, and its disappearance on incubation with glucagon, provided an elegant switching mechanism between the two opposing pathways of glycolysis and gluconeogenesis. The discovery was a landmark in the understanding of the control of liver carbohydrate metabolism and fructose 2,6-bisphosphate was subsequently shown to play a major role in controlling glycolysis in other tissues and in transformed cells. This article looks at the run-up to the discovery of fructose 2,6-bisphosphate and the years thereafter, with the background threat of transatlantic competition from the groups of Simon Pilkis and Kosaku Uyeda. We also review new developments on the bifunctional enzymes responsible for its synthesis and degradation (6-phosphofructo2-kinase/fructose-2,6-bisphosphatase) and the encoding genes since, in the cancer field, therapeutic targeting of fructose 2,6bisphosphate synthesis could be effective in halting tumour cell proliferation.

Transatlantic Competition Policy: Domestic and International Sources of EU-US Cooperation

This article employs a cross-level approach to explain cooperation in transatlantic competition policy. The explanation reveals the important role of regulators as interfaces between the domestic and international levels of analysis. Economic internationalization is a system-level cause of this cooperation, the precise effect of which is accounted for by an intervening variable (domestic politics), which is simplified with a principal-agent model. The negotiations over the 1991 EU-US Bilateral Competition Agreement suggest that, while regulators remain constrained by domestic institutions, they play an important role in explaining why the formal, transatlantic cooperative framework is largely a discretionary one created by a non-treaty international agreement.

Transatlantische Beziehungen

After World War II US-hegemony has been unchallenged in the capitalist part of the world. Therefore the US could afford to promote European integration. Meanwhile the economic foundations of the US' position have been weakened. First the superiority in terms of productivity got lost and after the New Economy boom there are also doubts about US-dominance on financial markets. This is the more so since the introduction of the Euro represents a major challenge for the Dollar. Nevertheless transatlantic competition on economic issues may not lead to a split as ruling classes in Europe and America share common interests against the rest of the world.

Transatlantic competition and European defence industries: a new look at the trade—defence linkage

The competitive environment of transatlantic economic relations has changed considerably in recent years, and this change generally has not been in favour of European industry and trade. The United States has reaffirmed its technological lead in a time of increasingly rapid technological change, and it is practising a new assertiveness in security and defence policy as well as in international trade policy and export promotion. This article analyses these developments and their implications for European defence industries as well as for Europe's industrial competitiveness and trade performance beyond the defence sector.

Anaesthesia

Instructor in Anesthesia Harvard Medical School Brigham and Women's Hospital 75 Francis Street Boston, Massachusetts 02115.Carol A. Hirshman, M.D., EditorAnaesthesia. Two Volumes. Second Edition. By W. S. Nimmo, D.J. Rowbotham, and G. Smith. Oxford, Blackwell Scientific Publications, 1994. Pages: 1,937. Price:$250.00.The preface to this second edition of Anaesthesia harbors a highly pertinent comment:“It may not be possible to provide within a single text all the knowledge for the anaesthetist but we see a clear need for modern anaesthetic practice to be summarized in one text….” With this concept, your reviewer agrees, and indeed, the authors have assembled a large, predominately British cast of coauthors with wide knowledge and experience. The two-volume set is divided into five sections totalling 92 chapters spreading over 1,937 pages. The first section undertakes a review of the pharmacology, physiology, physics, and statistics pertaining to anesthesia. Section 2 covers the complete gamut of subspecialty anesthesia. Section 3 embraces local anesthetic pharmacology, then local and regional anesthesia. Section 4 offers a spectrum of topics on acute and chronic pain. Section 5 deals with those few specific topics of intensive care that have significant bearing upon anesthesiologists' concerns in that realm.Common to all attempts to compose texts of anesthesia to cover all aspects of the practice, there is always a quandary as to where to end. Nimmo et al. clearly designate the target audience as those individuals sitting for Board or Fellowship examinations, and I commend their choice. However, they also offer the book as a “current readable and authorititative work for anaesthetists.” In both regards, I believe they have succeeded. The obvious current transatlantic competition is Anesthesia, edited by Professor Ronald D. Miller. I believe they are comparable texts.The authors have collected a fine coherent amalgam of topics in anesthesia, pain, and intensive care that have been well edited. There is considerable breadth in subject matter, and few instances of omission exist. For the most part, chapter quality is very high, yet some chapters disappoint, usually because of superficial coverage of rather complex problems. I sensed that the descriptions of the physiology and pathophysiology of the coronary and cerebral circulation were too superficial even for such a general text. Despite the inclusion of a chapter “Crystalloid Fluid Therapy,” the complex and frequently debated crystalloid-colloid controversy that plagues anesthetic practice was dealt with in only two pages. A singular disappointment is the absence of a cogent discussion of right ventricular failure and pulmonary hypertension along with its therapy. Concomitantly, pulmonary vasodilators are poorly dealt with. The chapter on artificial ventilation disappointingly fails to discuss permissive hypercapnia or ventilation with helium/oxygen mixtures. The chapter on breathing circuits and vaporizers still includes low-resistance in-circuit vaporizers, which should be, by now, no longer a facet of practice. Other chapters that suffer from supertificiality are those on liver disease and plastic surgery. Inevitably, there is the occasion for repetition when many authors collaborate in one text, yet with a few exceptions there is little redundancy in this text, the only notable examples being assessment of myocardial risk and preoperative assessment. I would like to commend the editors for including a brief supplemental reading list for each chapter in addition to the extensive reference lists.Despite this seemingly lengthy discussion of individual criticisms, the text is a highly sound compendium of knowledge with a justifiable strong, didactic clinical emphasis. Moreover, some specific chapters impressed. I mention them, not to denigrate the other chapters in an excellent text, but because they impressed greatly. These included chapters on anesthesia and cardiac disease, ventilatory failure, monitoring, and opioids. I was gratified by the inclusion of chapters about operating room/postanesthesia care unit management and design, as well as a comprehensive chapter on audit of anesthetic practice. These reflect sound, modern progress in the development of our specialty beyond the hackneyed phrase “passing gas” sometimes invoked by our detractors.Often, the topics poorly dealt with in anesthesia texts are those on statistics and epidemiology. These are superbly discussed here in a sound, concise chapter. Additionally, so often sections on intensive care and pain are poorly thought-out addendums to texts. This is not the case in this reference work. They are well collated topics applicable to the general practice of anesthesia.In summary, this is a fine text and a solid, well thought-out compendium of the practice of anesthesia as envisioned on both sides of the Atlantic. It befits its stated target audience well and should prove to be a sound preparatory text for anesthesiologists-in-training as well as a reference for graduates.Simon Body, M.B., Ch.B., Instructor in Anesthesia, Harvard Medical School, Brigham and Women's Hospital, 75 Francis Street, Boston, Massachusetts 02115.