Transatlantic Differences Research Articles

Governing the digital economy: transatlantic accommodation and cooperation

ABSTRACT The digitalization of the economy has brought significant benefits but also poses risks. These risks prompted first the European Union and subsequently China and the United States to adopt regulations. The three powers are seen to have very different regulatory approaches – the US deferring to the market, China prioritizing the government, and the EU protecting the individual – and to be exporting their models. As a result, many commentators contend that the digital economy is conflictual. Drawing on evidence from the contributions to the special issue, this article challenges two conventional wisdoms about the transatlantic digital relationship. First, it argues that transatlantic regulatory differences have been rooted in politics rather than principled differences. Second, rather than rule differences and jurisdictional conflict being virtually synonymous, transatlantic differences in approaches to governing the digital economy almost never led to conflict and, even then, cooperation was preferred.

Transatlantic differences in the use and outcome of minimally invasive pancreatoduodenectomy: a comparative analysis of four pancreatic surgery audits

Transatlantic differences in the use and outcome of minimally invasive pancreatoduodenectomy: a comparative analysis of four pancreatic surgery audits

Social responsibility and bank resiliency

We find strong evidence that measures of social responsibility contribute to increasing the resilience of banks. This finding holds when social responsibility is measured by aggregated ESG scores provided by Thomson Reuters, both according to their older Asset 4 categorization and to the reformed ESG Refinitiv classification, and resilience is proxied by various measures of systemic and systematic risk. The results hold on the level of subcategories of the ESG pillars, where we find that, particularly, variables related to the long-term perspective enhance resilience. Moreover, in our international study, we find significant transatlantic differences.

Serving in the Household and the Imagination: The Brontës, Alcott, and the Interconnected Roles of a Neglected “Transatlantic” Female Figure

Tabitha Aykroyd, Martha Brown, Nancy and Sarah Garrs were just a few of the very many girls and women working as domestic servants in early Victorian Britain. The main purpose of this article is to analyze the precise context and conditions in which they were employed in Haworth Parsonage, where the Brontë sisters lived for most of their lives (1820–1855), and the influence that they had on the well-being of this famous family and on the imagination and literary activity of the sisters. Aspects connected with the following will be explored and problematized: the value and respect that the Brontës attributed to or showed these domestic laborers and their work, including sharing in their tasks and duties; brief but useful connections of these figures with the sisters’ own professional activities as middle-class women (namely, when serving as teachers and governesses themselves); and also comparison with some relevant literary representations of the figure and role of the “female servant” in the Brontës’ novels. A complementary purpose is of a more transatlantic nature: to compare their earlier British domestic context with Louisa May Alcott’s later American one, and their literary representations of the female servant with Alcott’s own extensive treatment of that neglected figure in some of her fictional works. The justification for this comparison does not lie so much in the known influence that the works written by the Brontës, in particular Charlotte’s, had on Alcott, but more in their sharing of very similar concerns as regards this topic, in spite of very specific (transatlantic) differences that can be revealing of their respective attitude towards servitude.

Russian Civil Law in the Light of Transatlantic Differences in Legal Thought

The paper states that recently changes have been made to the procedural codes, which actually led to the legislative recognition of judicial practice as a source of substantive law (including civil law). Judicial practice, at least since the mid-90s of the last century, has not stopped trying to master the law-making function, the intensity of which has significantly decreased after the Supreme Arbitration Court of the Russian Federation ceased its operation. The science of civil law, represented by a large group of scholars, has also taken the path of justifying the search for law beyond the law. The paper substantiates the idea that this «ultra-American» trend does not correspond to the social conditions of Russia. Russian civil law should return to its German origins, which implies the search for law exclusively within the framework of the law. At the same time, the concept of legal interpretation and law enforcement borrowed in Germany should be supplemented with a rationalistic doctrine of legal interpretation. This approach will replace intuitive jurisprudence, covered by references to the «meaning» of legislative and other regulations.

Circles, Clocks, Ships, and Wires: Meridian Circles within Innovative Assemblages in 19th-Century America

Driven by needs to map an expanding nation as well as by pure astronomical inquiry, nearly 50 meridian circles were installed in 19th-century U.S. observatories. In the 1840s, U.S. astronomers used meridian circles in conjunction with chronometers on fast steamships to ascertain transatlantic longitude differences. Simultaneously, they devised methods of using meridian circles with newly invented telegraph technologies, which revolutionized longitude determination, productivity of data collection within observatories, and distribution of time signals. 19th-century U.S. astronomers and artisans also designed improvements to meridian circles themselves; by century end, U.S.-based instrument makers dominated the domestic meridian circle market over English and German artisans.

Sovereignty or Security? Maintaining Peace and The Ambivalent Relationship Between Europe and Washington, 1945–1991

Among historians, there has been a recurring debate on whether European states lost their de facto sovereignty during the Cold War (1945–1991). While Orthodox Cold War historians claimed that the Europeans were nothing more than chess pieces of the two opposing superpowers, others argued that the continental nations retained autonomy and contributed significantly to the war effort. In response to the academic discussion, this article aims to clarify whether Western European states traded their sovereignty for nuclear and diplomatic protection from the USA. By comparing the policies adopted by Washington and the Europeans – namely the British and French, respectively – I attempt to elucidate the scale of their disagreements and provide a clear analysis of the issue at hand. Upon research, the related literature and first-hand historical sources have demonstrated that: (1) Britain and France played an essential role in initiating the Cold War; (2) Western European states carried out foreign policies that were not in line with Kissinger’s direction during the 1960s and 1970s; (3) Transatlantic diplomatic differences remained in certain policy directions during the 1980s and early 1990s. In general, despite being close strategic allies of Washington, the European states retained their decision-making power.

Transatlantic Comparison of Pediatric Continuous Glucose Monitoring Use in the Diabetes-Patienten-Verlaufsdokumentation Initiative and Type 1 Diabetes Exchange Quality Improvement Collaborative.

Achieving glycemic targets in youth and young adults with type 1 diabetes (T1D) is challenging. Diabetes devices, including continuous glucose monitors (CGM) may impact glycemic control. We analyzed the proportion of CGM use in youth and young adults with T1D at nine U.S. T1D Exchange Quality Improvement (T1DX-QI) Collaborative centers and 402 European diabetes prospective follow-up registry (Diabetes-Patienten-Verlaufsdokumentation [DPV]) sites from 2017 to 2020 and examined the association of CGM use to glycemic control as measured by hemoglobin A1c (HbA1c). CGM use increased each year from 2017 to 2020 across all age ranges (<6, 6-<12, 12-<18, 18-<25 years) in both registries and lower mean HbA1c was observed in CGM users compared with nonusers regardless of insulin delivery method for all years analyzed. CGM use appeared to increase more so in the European DPV than the U.S. T1DX-QI, which may be due to transatlantic differences in health care systems, insurance coverage, and prescriber habits.

The Great, Gray City of Light

AbstractThis essay analyzes one of James Baldwin’s least commented-upon essays, “Equal in Paris,” through the lens of current debates about transatlantic differences regarding race, equality, and citizenship. In his essay, Baldwin narrates how he was imprisoned in Paris for several days a year after his arrival in France. Baldwin constructs his essay not as a political manifesto about race, citizenship, and equality. Rather, through a powerful and cinematographic description, he leads the reader to share the narrator’s distressing experience of disjunction and terror he had while in prison. This literary choice can be understood in the context of Baldwin’s rejection of theologies of damnation and redemption that, according to him, motivate protest writings.

Varieties of neoliberalism: courts, competition paradigms and the Atlantic divide in anti-trust

AbstractEuropean anti-monopoly rules are now more intensively enforced than those in the USA, in contrast to the historical pattern. In this article, I evaluate the reasons why, using a combination of historical analysis of legal developments and empirical analysis of the pattern of enforcement and judicial review. Transatlantic differences in economic interests, business power, and the relative influence of economists cannot fully account for the policy divide. American and European anti-trust policy are structured by distinct competition paradigms, which have been institutionalized by courts through case law. In the USA, a laissez-faire jurisprudential regime has blocked or discouraged anti-monopoly enforcement. In Europe, an ordoliberal jurisprudential regime has facilitated a more intensive enforcement program. In highlighting how case law structures regulatory paradigms, the analysis shows that courts can contribute to both ideational continuity and change in economic policy.

Labour Market Responses to the COVID-19 Crisis in the United States and Europe

Labour markets have reacted very differently to the COVID-19 crisis. In the US, the impact on unemployment rates was rapid across all states. They increased sharply in March and April 2020 and recovered steadily thereafter. In Europe, by contrast, unemployment increased far less, and the adjustment was more gradual.This difference in unemployment responsiveness is most likely a consequence of the widespread use of short-term work schemes in Europe, given that the transatlantic differences in hours worked overall are much smaller than for unemployment.Using data from US states and EU member states, an econometric analysis of the impact of the restrictions (lockdowns) implemented by governments to contain the spread of the virus reveals that in the case of the US, unemployment appears to have been driven mostly by the aggregate shock generated by the pandemic as it played out between March and November 2020. In the EU, unemployment showed little variation. The Non-Pharmaceutical Interventions (NPIs) used in different US states and EU countries, as can be demonstrated through a regression analysis, did not always have significant effects on unemployment.

Climate and Literature ed. by Adeline Johns-Putra

Reviewed by: Climate and Literature ed. by Adeline Johns-Putra Jay Labinger (bio) Adeline Johns-Putra, ed., Climate and Literature. Cambridge: Cambridge University Press, 2019, 346 pp. $120 hardback. One might expect a new book sporting this title to be mainly about literary responses to anthropogenic climate change, which has played such a large role in public discourse over the last few decades. While that certainly is one focus of this collection of essays by a number of (primarily American and English) scholars, the scope of the work is much broader, tracing connections between climate and literature all the way back to the beginnings of the latter—and the former as well: climate and literature have always been inextricably linked, in an important sense, as editor Adeline Johns-Putra proposes in her introduction: "climate emerges discursively… [it] necessarily possesses an intimate relationship with language, and through language, to literature" (pp. 1–2). The work consists of seventeen chapters (besides the introduction), grouped into three sections. Part I, "Origins," opens with Robert Markley's "Literature, Climate, and Time," which considers in some detail several works from the nineteenth and twentieth centuries, but also exposes more general issues that reappear frequently in subsequent chapters: turning points in the historical representation of climate in literature; the potential utility of literary treatment of climate; the association of climate literature with science fiction; and the relationship between religious belief and climate thinking. (I will defer discussion of these common themes until all the essays [End Page 235] have been introduced.) Chapter 2, by Jesse Oak Taylor, concentrates on atmosphere as both literal and figurative component of the novel, taking Wuthering Heights as the prime exemplar; it is followed by Tess Somerwell's account of how the cycle of seasons figures in (European) literature as a link between nature and culture. The remainder of part I, and the book as a whole, follows a mostly chronological arc. In "Climatic Agency in the Classical Age," Daryn Leboux notes that someone (possibly Hippocrates, but that is not definitively known) claimed "one can attribute the characteristics of individual cities, of whole nations, and even whole regions, to their climates" (p. 72). P. S. Langeslag moves ahead to the medieval period, addressing two aspects: the prominent setting of borderline-habitable climates in Norse literature, and the part played by climate in "end-time" writings in the medieval church. The section closes with an essay on Shakespearean climate by Lowell Duckert, who—citing a pair of climate scientists who place the start of the Anthropocene in 1610—argues for its relevance to our own climate thinking. Part II is labeled "Evolution;" its first chapter, by historian of science Jan Golinski, suggests that the Enlightenment brought about a major alteration of our conceptions of weather and climate. Particularly in Britain, increased attention to the measurement and recording of data led people "to conceive of weather as a constant—and not merely occasional—presence in human lives" (p. 111). The perception of extreme weather events as manifestations of divine intervention gave way to a more stable view of climate, and even to early belief that climate could be altered—improved, specifically—by human activity, thus ameliorating the inhospitable North American environment towards one more like Europe, better fit for civilized people. The next two chapters amplify those themes: David Higgins's "British Romanticism and the Global Climate" explores literary responses to the climatic effects of two immense volcanic eruptions around the turn of the nineteenth century, while Morgan Vanek looks into how transatlantic climate differences influenced political developments of the period. Jessica Howell shows how the theme of climate as cultural determinant informed thinking about race and empire in writers such as Burton, Conrad, and Kipling. The last three chapters in this section take us into the 1900s. Justine Pizzo's "Ethereal Women: Climate and Gender from Realism to the Modernist Novel" harnesses the multivalent word "ethereal" to relate climate and feminine spirituality in works from the Victorian era through the first half of the twentieth century, followed by Chris Pak's examination of the theme of terraforming in several classic twentieth-century science fiction novels (Arthur C. Clarke's The Sands of...

“Buying on time”

Consumer credit has been central to the history of small loans since the late 19^th century. Debates over credit buying (or “buying on time”) reveal fundamental assumptions about imagined futures and pasts in modern economies. Credit buying often built on expectations of future growth and improved living standards. Still, debates over credit highlight social anxieties also invoked an imagined past of supposedly more frugal household financing. Taking the German debate as a vantage point, the article deconstructs both the myth of a prewar past built on cash buying and contemporary fears of an “Americanized” future of debt-based spending. It explores transatlantic differences in the temporal perception of consumer credit. The final section examines shifts in consumer lending since the 1970s.

Social Responsibility and Bank Resiliency

We provide transatlantic evidence about the relation between social responsibility and resiliency in the banking industry. We analyse various measures of resiliency, an exposure measure (SRISK) and a contribution measure (Delta CoVaR) to systemic risk, as well as measures of systematic risk (beta) and insolvency risk (z-score). Social responsibility is measured by Thomson Reuters' ESG-scores and their subcategories, both according to the older Asset 4 and the present TR ESG Refinitiv classification. We find that the social aggregate score significantly enhances resiliency in all dimensions and in both classifications. On the level of subcategories, we identify significant common resiliency enhancing factor proxies for long-term orientation, such as product responsibility and workforce training, while short-term objectives proxied by shareholder orientation tend to relate to lower levels of resiliency. Looking deeper into the components of each ESG pillar, we also discover significant transatlantic differences mainly related to the different organization of labour markets as well as the board structure.

Edith Wharton's The Age of Innocence: New Centenary Essays

Edith Wharton's <i>The Age of Innocence:</i> New Centenary Essays

Transatlantic relations after the Covid-19 pandemic

This article analyses how the COVID-19 pandemic has affected the relationship between Europe and the US, and provides suggestions on how transatlantic cooperation should be taken forward. The pandemic has increased public distrust of the US in Europe due to the way the former has chosen to respond to COVID-19. However, this article argues that the pandemic has mainly accelerated existing transatlantic differences rather than creating new ones. To restore the transatlantic relationship, Europe and the US should strengthen their cooperation on common challenges such as climate change, health security, China, terrorism and migration. COVID-19 has highlighted the limitations of nationalist and unilateral policies in confronting global challenges. It may, in the end, provide the impetus for a rejuvenated transatlantic partnership and build a renewed sense of transatlantic solidarity.

Education in a Heterogeneous-Agent Economy: Revisiting Transatlantic Differences

I propose a novel heterogeneous-agent model featuring public and private education in the choice set of households, positive human capital externalities, and distortionary taxes for public education financing to study transatlantic differences in public versus private education investment, tax rates, and economic distributions. I show that exogenous tax differences alone can generate most of the observed transatlantic disparities in this model. I also demonstrate that this model can explain how either of the calibrated US and European tax regimes can gain public support due to the U shape of aggregate variables over taxes, as also seen in the data.

Divergent and linked selection shape patterns of genomic differentiation between European and North American Atlantic salmon (Salmo salar).

As populations diverge many processes can shape genomic patterns of differentiation. Regions of high differentiation can arise due to divergent selection acting on selected loci, genetic hitchhiking of nearby loci, or through repeated selection against deleterious alleles (linked background selection); this divergence may then be further elevated in regions of reduced recombination. Atlantic salmon (Salmo salar) from Europe and North America diverged >600,000years ago and despite some evidence of secondary contact, the majority of genetic data indicate substantial divergence between lineages. This deep divergence with potential gene flow provides an opportunity to investigate the role of different mechanisms that shape the genomic landscape during early speciation. Here, using 184,295 single nucleotide polymorphisms (SNPs) and 80 populations, we investigate the genomic landscape of differentiation across the Atlantic Ocean with a focus on highly differentiated regions and the processes shaping them. We found evidence of high (mean FST =0.26) and heterogeneous genomic differentiation between continents. Genomic regions associated with high trans-Atlantic differentiation ranged in size from single loci (SNPs) within important genes to large regions (1-3Mbp) on four chromosomes (Ssa06, Ssa13, Ssa16 and Ssa19). These regions showed signatures consistent with selection, including high linkage disequilibrium, despite no significant reduction in recombination. Genes and functional enrichment of processes associated with differentiated regions may highlight continental differences in ocean navigation and parasite resistance. Our results provide insight into potential mechanisms underlying differences between continents, and evidence of near-fixed and potentially adaptive trans-Atlantic differences concurrent with a background of high genome-wide differentiation supports subspecies designation in Atlantic salmon.

Chromosome polymorphisms track trans-Atlantic divergence and secondary contact in Atlantic salmon.

Pleistocene glaciations drove repeated range contractions and expansions shaping contemporary intraspecific diversity. Atlantic salmon (Salmo salar) in the western and eastern Atlantic diverged >600,000years before present, with the two lineages isolated in different southern refugia during glacial maxima, driving trans-Atlantic genomic and karyotypic divergence. Here, we investigate the genomic consequences of glacial isolation and trans-Atlantic secondary contact using 108,870 single nucleotide polymorphisms genotyped in 80 North American and European populations. Throughout North America, we identified extensive interindividual variation and discrete linkage blocks within and between chromosomes with known trans-Atlantic differences in rearrangements: Ssa01/Ssa23 translocation and Ssa08/Ssa29 fusion. Spatial genetic analyses suggest independence of rearrangements, with Ssa01/Ssa23 showing high European introgression (>50%) in northern populations indicative of post-glacial trans-Atlantic secondary contact, contrasting with low European ancestry genome-wide (3%). Ssa08/Ssa29 showed greater intrapopulation diversity, suggesting a derived chromosome fusion polymorphism that evolved within North America. Evidence of potential selection on both genomic regions suggests that the adaptive role of rearrangements warrants further investigation in Atlantic salmon. Our study highlights how Pleistocene glaciations can influence large-scale intraspecific variation in genomic architecture of northern species.

How information affects support for education spending: Evidence from survey experiments in Germany and the United States

To study whether current spending levels and public knowledge of them contribute to transatlantic differences in policy preferences, we implement parallel survey experiments in Germany and the United States. In both countries, support for increased education spending and teacher salaries falls when respondents receive information about existing levels. Treatment effects vary by prior knowledge in a manner consistent with information effects rather than priming. Support for salary increases is inversely related to salary levels across American states, suggesting that higher salaries could explain much of Germans' lower support for increases. Information about the tradeoffs between specific spending categories shifts preferences from class-size reduction towards alternative purposes. Additional German experiments indicate that information effects extend to specific reform proposals and to other areas of public spending.