Turbulent Waters Research Articles

Economic Crisis and Well-Being in Europe: Introduction

The financial and economic crisis began in 2007 in the United States and rapidly spread around the world. It was not a typical crisis taking place in a developing country; this crisis took place at the centre of the world economic system, and it had repercussions in many developed countries. As a consequence, many European countries have gone through a difficult period that threatens their citizens’ relatively-high quality of life. Countries in the region have faced increasing unemployment rates as well as the need of undertaking fiscal adjustments which undermine the generous social-welfare schemes which prevail in the region. In a region with a large population of migrants it should not be a surprise to see a differentiated impact of the crisis, hitting deeper in the quality of life of migrants. A crisis indicates that things are no longer as they used to be. It calls for greater attention to the practices countries used to follow as well as for new ideas in procuring people’s well-being. The profound and widespread effects of the crisis do also call for using indicators that fully capture the well-being situation in societies and which provide insight into the best ways to moving forward within turbulent waters. Social indicators, theories, and quantitative methods are necessary to measure and to develop an understanding of the impact of the crisis, as well as to be in a solid position to propose a way forward. With appropriate measurement indicators and with good theories it would be possible to make of the crisis an opportunity, finding new ways of procuring the well-being of people. The study of a crisis and the design of a way forward should not circumscribe to the analyses of productivity, competitiveness and economic-growth indicators; it should also take into consideration social indicators as well as specific marginalized populations.

Characterizing turbulent overturns in CTD-data

We are concerned with the shape of overturns due to irreversible effects of turbulent mixing through internal wave breaking in the ocean. Vertical (z) overturn displacements (d) are computed from ship-borne SeaBird-911 CTD-data using the well-established method of reordering unstable portions in vertical density profiles. When displayed as a function of z, the displacements d(z) reveal a characteristic zigzag shape. Here, we primarily investigate the particular slope (z/d) of this zigzag signature after assigning the displacements to the end-point depths. Using model-overturns we show that this slope equals ½ for a solid-body-rotation, while a more sophisticated Rankine-vortex overturn-model, here employed in the vertical, has slopes slightly >½ in the interior and >1 along the sides. In the case of a near-homogeneous layer, displacement-points fill a parallelogram with side-edges having a slope of 1. The models are used to interpret overturn shapes in NE-Atlantic-Ocean-data from moderately deep, turbulent waters above Rockall Bank (off Ireland) and from deep, weakly stratified waters above Mount Josephine (off Portugal). These are compared with salinity-compensated intrusion data in Mediterranean-outflow-waters in the Canary Basin. Dynamically, most overturns are found to resemble the half-turn Rankine-vortex model and very few a, small-only, solid-body-rotation. Additionally, the usefulness and uselessness of upcast-CTD-data are discussed for overturn characterization.

Anomalous diffusion and multifractality enhance mating encounters in the ocean

For millimeter-scale aquatic crustaceans such as copepods, ensuring reproductive success is a challenge as potential mates are often separated by hundreds of body lengths in a 3D environment. At the evolutionary scale, this led to the development of remote sensing abilities and behavioral strategies to locate, to track, and to capture a mate. Chemoreception plays a crucial role in increasing mate encounter rates through pheromone clouds and pheromone trails that can be followed over many body lengths. Empirical evidence of trail following behavior is, however, limited to laboratory experiments conducted in still water. An important open question concerns what happens in the turbulent waters of the surface ocean. We propose that copepods experience, and hence react to, a bulk-phase water pheromone concentration. Here we investigate the mating behavior of two key copepod species, Temora longicornis and Eurytemora affinis, to assess the role of background pheromone concentration and the relative roles played by males and females in mating encounters. We find that both males and females react to background pheromone concentration and exhibit both innate and acquired components in their mating strategies. The emerging swimming behaviors have stochastic properties that depend on pheromone concentration, sex, and species, are related to the level of reproductive experience of the individual tested, and significantly diverge from both the Lévy and Brownian models identified in predators searching for low- and high-density prey. Our results are consistent with an adaptation to increase mate encounter rates and hence to optimize reproductive fitness and success.

Sinking or swimming in the deep end? Developing professional academic identities as doctoral students chairing large classes

Much of the burden of undergraduate teaching in Australian higher education institutions falls to sessional staff and postgraduate students. These members of staff assume high teaching loads and administrative management responsibilities. This paper explores the perspectives of two female academics in the unique position of being the subject co–ordinators for large first–year psychology units (around 1600 students) whilst still being doctoral (PhD) candidates. This situation raises interesting issues around the creation of academic identity. Using the metaphor of sinking or swimming in the deep end, we explore strategies to navigate the often turbulent waters of working in academia without drowning in teaching and administration, whilst attempting to stay afloat with doctoral research.

Prey Detection and Feeding Success of the Comb Jellyfish Mnemiopsis leidyi on Copepods in Still and Turbulent Waters

The comb jelly or ctenophore, Mnemiopsis leidyi, is a voracious predator in both its native and non-native habitats. Though M. leidyi inhabits coastal waters that are frequently turbulent, previous feeding studies have been conducted in still water tanks. This study aimed to research feeding behaviors in turbulent waters, which is more representative of the natural environment. Interactions between the free-swimming ctenophores and copepod prey, such as Acartia tonsa, were observed and recorded in a laboratory turbulence tank (n = 73). Turbulence was created using submersible speakers, and the interactions were recorded using a video camera. Capture efficiency denoted interactions containing direct contact between copepods and M. leidyi that led to eventual capture, frequently after multiple contacts. Overall copepod capture efficiency was similar in still (48%) and turbulent (43%) water, as were the overall prey retention rates for each (still = 58%; turbulent = 57%). However, M. leidyi exhibited anticipatory responses, defined as altering the position of feeding structures, nearly twice as often in still (41%) waters than in turbulent (20%) waters. The hydromechanical “noise” produced by background turbulence may inhibit the capacity of the ctenophore to detect and respond to fluid motions produced by its prey.

Book Review: A Right to Offend: Free Expression in the Twenty-First Century, by Brian Winston

A Right to Offend: Free Expression in Twenty-First Century . Brian Winston. London, UK: Bloomsbury Academic, 2012. 432 pp. $140 hbk. $40.95 pbk.The year 2013 is an especially fitting time to review a book about offensive expres- sion. It is, after all, 25th anniversary of U.S. Supreme Court's landmark ruling in Hustler Magazine v. Falwell. That decision protected pornographer Larry Flynt's right under First Amendment to U.S. Constitution to parodically suggest that Reverend Jerry Falwell, head of Moral Majority and Thomas Road Baptist Church, had sex with his mother in a fly-infested outhouse and preached while drunk. The parody closed with Falwell rhetorically querying, You don't think I could lay down that bullshit sober, do you?The right to offend, however, is no laughing matter today across much of world, given a number of sobering events. For instance, deadly violent protests in September 2012 in response to a low-budget, anti-Islamic video called Innocence of Muslims demonstrate that whether such a right even exists in some countries and cultures is very much in doubt. It is into such turbulent waters that Brian Winston's timely tome, A Right to Offend, wades deeply, internationally, and comprehensively.Spanning more than 400 pages, book covers a vast amount of territory, from censorship of writings of Martin Luther in 1500s through so-called Hackgate scandal of 2011 involving Rupert Murdoch's News of World and journalists infil- trating cell phone messages and texts of dozen of individuals. In between are more than three dozen incidents and controversies involving censorship in United Kingdom and United States that serve as pegs for author's points.The book includes an eclectic mix of characters, from double A (Julian Assange and Amos nAndy) to double Z (John Peter Zenger and Emile Zola). And, yes, Falwell case is discussed, but only briefly and standing for obvious yet important proposition that had Supreme Court ruled for reverend, all American televi- sion satire from Saturday Night Live through to The Daily Show with Jon Stewart might well have been jeopardized.Despite wide range of material covered, book charts a clear trajectory. Part I reveals what Winston calls prosecution of free expression, while Part II comes to free expression's defense. Winston ultimately concludes with ten bullet-pointed suggestions supporting his fundamental belief that the right to free speech and right within it to offend, because without it we have no free speech, must be main- tained. At whatever cost.Winston's thesis is well articulated. While he once believed right to engage in offensive expression had been firmly won in Western Europe and United States, that changed in February 1989 when Iman Ruhollah al-Musavi al-Khomeni issued a fatwa targeting Salman Rushdie for his novel, The Satanic Verses. For Winston, who points out that a copy of Rushdie's book lies on desk as this is being typed, fatwa was a game-changer that created a new template for anybody affronted by a specific act of free expression to respond with an aggression previously unseen, via its extra-territorial, quasi-judicial sanctioning of mob rule and murder to suppress expression. …

The Rise of Christian Zionism

For historians of American foreign relations, one of the most difficult relationships to analyze and discuss has been that between the United States and Israel. It is not surprising that historiography in this field has at times lurched between strongly opposing interpretations or failed to delve into complexities in order to avoid uncomfortable controversies. Caitlin Carenen wades into these turbulent waters and emerges with a refreshingly multilayered study which grapples with the intersections of government relations, domestic political evolution, and religious philosophies. Carenen’s book can be read on a number of different levels. First, it explains the increasingly sympathetic relationship between the United States and Zionism. This chronological story takes us from the 1930s to the end of the George W. Bush administration, and answers political questions about when the two countries had a more distant or a closer relationship. Second, the book maps out how the strengthening political relationship between the two governments paralleled and intersected with the growing support for Zionism among organized Protestant groups, beginning with liberal, mainline organizations, and then among evangelical groups. Third, Fervent Embrace is about the shift of political power in American society from one dominant Protestant group to another: Liberal, mainline to evangelical. Fourth, in tracing this power shift among Protestants, Carenen also shows the philosophical shift within Christian Zionism. She explains how the justifications for Zionism were different at different points in the century and among different Protestants. And, finally, Carenen addresses the most controversial lightening rod in the discussion of the American-Israeli relationship: The connection between antisemitism and support for or opposition to Israel.

Turbulent Waters: Sea Raiding in Early Modern South East Asia

Between 1500 and 1860 piracy in South East Asia was a multinational enterprise, involving European, American, Chinese, Japanese, and indigenous sea raiders. Although Western pirates occasionally made their way into South East Asian waters, they never posed as much of a threat to the prosperity and stability of the area as the buccaneers had done in the Caribbean. Their presence virtually disappeared in the archipelagos by the early eighteenth century. Chinese and Japanese pirates also sporadically infiltrated the area during the entire period, and indigenous forms of piracy continued and expanded throughout the whole region during the eighteenth and nineteenth centuries.

A Rock Amidst Turbulent Waters: China’s Resilient Centre and its Machiavellian Management of Protests and Petitions

A Rock Amidst Turbulent Waters: China’s Resilient Centre and its Machiavellian Management of Protests and Petitions

Changing of the Guard

In the five years since the Emerging Health Threats Journal published its first issue, a steady stream ‘‘100- year’’ events has increased awareness of the multitude of threats to human health. This month, the Journal is announcing a change at the helm: I will be taking over the position of Chief Editor from Andrew Robertson, who was instrumental in crafting the Journal’s unique vision and provided exemplary leadership from its founding. Dr. Robertson has graciously agreed to transition to Associate Editor, in which role he will continue to help chart the Journal’s course through the increasingly turbulent waters of world health crises. (Published: 8 February 2013) Citation: Emerg Health Threats J 2013, 6 : 20449 - http://dx.doi.org/10.3402/ehtj.v6i0.20449

The Assembling of Schooling: Discussing Concepts and Models for Understanding the Historical Production of Modern Schooling

Several notions have been proposed to understand the specificity of schooling and its persistence across time and space, despite several attempts to reform it. In this article, the author analyses more closely the notions of the ‘grammar of schooling’, ‘forme scolaire’, and ‘school organisational culture’. These notions have also been used to address the global expansion of schooling and the adoption of similar structures and visions, in a process coterminous with westernisation and colonialism. The author reads the three of them together and analyses with some detail what they say about schooling as well as some of their blind spots. She then presents two alternatives to what she perceives to be their shortcomings: first, a historical and anthropological approach to school culture; and second, Bruno Latour's notion of networks and assemblages. While the two of them are not exclusive of each other, they have tended to grow different intellectual projects that are discussed here. While acknowledging that theorising might be a risky project, the author argues that researchers have a lot to gain from navigating these turbulent waters, producing a grounded, local theory that illuminates the ‘more than one, less than many’ configurations of schooling.

Understanding patent eligibility of new technology in the United States

As entirely new technologies have developed over the past two centuries, US patent law has struggled with questions over whether that type of technology should be protectable by patent grants, and if so, to what extent. Historically, this issue was presented with the development of life-changing technologies like the telegraph and telephones. More recently, the challenge has been presented with the development of computers and software, financial innovation, the Internet and e-commerce applications. We also see these challenges arising in the life sciences with new methods to diagnose and treat diseases, as well as the isolation and mutation of human and animal genes to create new medical treatments. These types of new development have always presented a theoretical strain on the underlying rationale for the US patent system, and today is no exception. This article seeks to provide some guidance on the current state of the law, with its evolving and constantly changing standards, and provide tips and best practices on how to navigate the turbulent waters for determining patent-eligibility.

A Conversation with T. R. Hummer

A Conversation with T. R. Hummer Andrew McFadyen-Ketchum (bio) Click for larger view View full resolution [End Page 82] T.R. Hummer was born on August 7, 1950 and grew up on his family’s farm in rural Macon, Mississippi. Throughout high school he played the saxophone and received his BA and MA in writing from the University of Southern Mississippi in 1974. Two years later, his first collection of poetry, Translations of Light, was released by Cedar Creek Press, and in 1977 he became a PhD student at the University of Utah, where he worked under the tutelage of poet Dave Smith. Since that time, Hummer has published eight full-length collections of poetry: The Angelic Orders (1982), The Passion of the Right-Angled Man (1985), Lower-Class Heresy (1987), The Eighteen-Thousand-Ton Olympic Dream (1990), Walt Whitman in Hell: Poems (1996), Useless Virtues (2001), Bluegrass Wasteland: Selected Poems 1978–2003 (2005) and The Infinity Sessions (2005). He has served as editor of numerous highly influential journals across the country including the Kenyon Review, the New England Review, and the Georgia Review. He has also published a book of essays, The Muse in the Machine: Essays on Poetry and the Anatomy of the Body Politic. T.R. Hummer continues to play the saxophone while teaching creative writing at Arizona State University and maintaining several blogs on music, writing, culture, and politics. His ninth collection of poetry, Ephemeron, is due out with the LSU Press’s Southern Messenger Poetry Series in 2011. This conversation took place in February 2011. [End Page 83] Andrew McFadyen-Ketchum: Looking at your body of work is, well, intimidating. Over the last twenty-five years you’ve managed not only to be an enormously prolific and well-received poet but also to become a highly respected professor, editor and essayist. You’re a dedicated family man, blogger and musician. How do you manage it all? T. R. HUMMER I work cheap. Therefore I work fast, when I work. It seems to me that I waste a lot of time, but one of the good things about being an artist is that nothing is ever really wasted. Music feeds poetry which feeds essays (and blogs and other prose) which feeds teaching which feeds the family. And everything I read and write goes into the cosmic poem hopper. So over time work accrues like flakes on a snowbank. AMK I first encountered your work at a reading you gave from Useless Virtues at Virginia Tech. What I remember most about that night was your reading of the last few pages of “Walt Whitman in Hell,” which ends with the speaker’s final observations of the modern world’s failings: . . . Maybe that is why— Over the conspicuous roofs of your living Beauty shops, sweatshops, pawnshops, printshops, meat shops, Warehouses, bathhouses, crackhouses, penthouses, card houses— Once and for all unhearable, and for all I know unthinkable, I go on Sounding my doomed eternal bodiless goddamned I, I, I, I, I. Of this book, Garrett Hongo has said, “Hummer presents us with a hectoring witness compelled to translate the banal urban atrocities of our current civilization into complex testimonies and transcendent prophecies.” Fred Chappell echoed this sentiment. Your book Ephemeron is similarly critical of American culture and, like Whitman, simultaneously loving. You are one of the few contemporary American poets who has been able to so successfully [End Page 84] navigate such turbulent waters. Why has this approach worked so well for you, and why do you so often feel compelled to write about American culture and its flaws? HUMMER About half a lifetime ago I began to glimpse the possibility of a model of writing poems that it has taken me a long time to even begin to bring to fruition. Perhaps I’m not there yet. Much of the model comes from Whitman—a poet who people often claim to emulate without even playing in the same concert hall. Whitman wrote out of the mind of the body politic. His “I” is not an “I” at all in the usual sense, even though it sometimes says, “I am Walt Whitman.” For him, this process was...

Russia under Putin: Titanic looking for its iceberg?

December 2011 protests in Russia, the largest after the collapse of the Soviet Union, shattered the status quo that had taken shape over the last decade and signaled that Russia is entering turbulent waters. Russia found itself caught in a trap: the 2011–2012 elections perpetuate a personalized power system that became the source of decay. The top-down rule and its “personificator” – Vladimir Putin – are already rejected by the most dynamic and educated urban population. However, no clear political alternative with a broad social support has yet emerged to replace the old Russian matrix.In terms of strategic significance, Putin's regime will most certainly unravel in the foreseeable perspective. But it is hard to predict what consequences this will have: the system's disintegration and even collapse of the state, growing rot and atrophy, or the last grasp in the life of personalized power and transformation that will set Russia on a new foundation. One thing is apparent: transformation will not happen in the form of reform from above and within, and if it does occur, it will be the result of the deepening crisis and society's pressure.

ANCHORS IN A PROFESSIONAL STORM

Professional service firms — the ones traditionally hired to help other businesses — have increasingly found themselves in rough waters. Dominic Houlder, Bernhard Kerres and Harry Korine believe that these firms need to change. But, first, they must ensure that they have anchors to keep them from drifting into turbulent waters that could destroy them.

Aquatic bryophytes as ecological indicators of the water quality status in the Tiber River basin (Italy)

A survey of 18 watercourses of the Tiber River basin was carried out to define the ecological niche breadth of some aquatic bryophyte species in relation to environmental factors. Aquatic bryophytes were sampled and water environmental parameters were measured at 99 stations distributed along the catchment (from the headwater regions to the downstream reaches). The datasets of the collected species and environmental data were analyzed by using a multivariate statistical analysis (PCA biplot). Ecological responses of the recorded aquatic bryophytes were obtained using a fuzzy set approach, and were compared with data from literature. The results show that the presence of the aquatic bryophytes in watercourses is affected negatively by the reduction of water velocity, clearness, substratum size and the worsening quality of the water physico-chemical status. In fact, aquatic bryophytes show a general preference for stations characterized by medium-large granulometry, and fast-flowing, clear, oxygenated (mean value 9.2 mg/l), cool waters (mean value 15.0 °C), with low loads of nutrients, particularly ammonia (mean value 0.10 mg/l) and phosphates (mean value 0.09 mg/l). However, ecological responses reveal different patterns in the distribution of aquatic bryophyte species mainly in relation to water physico-chemical parameters (e.g. temperature, conductivity, ammonia, phosphates). E.g. Palustriella commutata var. commutata, Cratoneuron filicinum, Fissidens viridulus and Cinclidotus aquaticus show high preference for clear, turbulent and fast-flowing waters, with temperature below 12 °C, conductivity below 300 μS/cm, and concentrations about 0.01 mg/l for phosphates, not exceeding 0.10 mg/l for ammonium ions and 0.90 mg/l for nitrates. Leptodictyum riparium and Riccia fluitans are for their part more linked to turbid and slow waters affected by eutrophication, showing optimum values for about 0.30 mg/l for ammonia concentration, 0.90 mg/l for nitrates and 0.11 and 0.22 mg/l for phosphates respectively. Conversely, Fontinalis antipyretica is not closely related to specific conditions, showing wide ecological ranges for most of the analyzed environmental factors. This paper has evaluated and discussed the possible use of sampled species as bioindicators for biomonitoring of the water quality.

Part II of a series on women as adjuncts: Navigating the Turbulent Waters of Adjunct Teaching

Part II of a series on women as adjuncts: Navigating the Turbulent Waters of Adjunct Teaching

Centennial-scale changes to the aquatic vegetation structure of a shallow eutrophic lake and implications for restoration

SUMMARY 1. We investigate long-term (>200 years) changes to the composition and spatial structure of macrophyte communities in a shallow, eutrophic lake (Barton Broad, eastern England) and consider the implications for lake restoration. 2. Historical macrophyte data were assembled from a variety of sources: existing plant databases, museum herbaria, journal articles, old photographs and eyewitness accounts. Additionally, two types of sediment core sample were analysed for plant macro-remains and pollen; bulk basal samples from multiple core sites analysed to provide information on ‘pre-disturbance’ macrophyte communities and two whole cores analysed to determine historical change. 3. Prior to the late 1800s, macrophyte communities were diverse and included a multilayered mosaic of short-stature submerged taxa and taller submerged and floatingleaved species. With the progression of eutrophication after around 1900, the former community was displaced by the latter. Diversity was maintained, however, since an encroaching Schoenoplectus–nymphaeid swamp generated extensive patches of low-energy habitat affording refugia for several macrophytes otherwise unable to withstand the hydraulic forces associated with open water conditions. When this swamp vegetation disappeared in the 1950s, many of the ‘dependent’ aquatic macrophytes also declined leaving behind a sparse, species-poor community (as today) resilient to both eutrophication and turbulent open waters. 4. The combination of historical and palaeolimnological data sources offers considerable benefits for reconstructing past changes to the aquatic vegetation of lakes and for setting restoration goals. In this respect, our study suggests that successful restoration might often be better judged by reinstatement of the characteristic structure of plant communities than the fine detail of species lists; when nutrients are low and the structure is right, the right species will follow.

A Seismic Landstreamer Survey at the Hanford Site, Washington, U.S.A

Research Article| August 01, 2011 A Seismic Landstreamer Survey at the Hanford Site, Washington, U.S.A EMMA R. HYDE; EMMA R. HYDE Search for other works by this author on: GSW Google Scholar MARVIN A. SPEECE; MARVIN A. SPEECE 1. Corresponding author email: mspeece@mtech.edu Search for other works by this author on: GSW Google Scholar CURTIS A. LINK; CURTIS A. LINK Search for other works by this author on: GSW Google Scholar TED R. REPASKY; TED R. REPASKY Search for other works by this author on: GSW Google Scholar MICHAEL D. THOMPSON; MICHAEL D. THOMPSON Search for other works by this author on: GSW Google Scholar STEVEN F. MILLER STEVEN F. MILLER Search for other works by this author on: GSW Google Scholar Environmental & Engineering Geoscience (2011) 17 (3): 227–239. https://doi.org/10.2113/gseegeosci.17.3.227 Article history first online: 02 Mar 2017 Cite View This Citation Add to Citation Manager Share Icon Share Twitter LinkedIn Tools Icon Tools Get Permissions Search Site Citation EMMA R. HYDE, MARVIN A. SPEECE, CURTIS A. LINK, TED R. REPASKY, MICHAEL D. THOMPSON, STEVEN F. MILLER; A Seismic Landstreamer Survey at the Hanford Site, Washington, U.S.A. Environmental & Engineering Geoscience 2011;; 17 (3): 227–239. doi: https://doi.org/10.2113/gseegeosci.17.3.227 Download citation file: Ris (Zotero) Refmanager EasyBib Bookends Mendeley Papers EndNote RefWorks BibTex toolbar search Search Dropdown Menu toolbar search search input Search input auto suggest filter your search All ContentBy SocietyEnvironmental & Engineering Geoscience Search Advanced Search Abstract The Hanford Nuclear Reservation, located in south-central Washington, U.S.A., is the site of a large-scale and ongoing environmental cleanup effort, which includes the remediation of radionuclide- and chemical-contaminated groundwater. Identification of preferential pathways for groundwater contaminant flow near the top of the Columbia River Basalt Group is critical for the groundwater cleanup effort. High-resolution shallow seismic surveys were conducted using a 96 channel landstreamer with gimbaled geophones on the Hanford Central Plateau near the Gable Gap area of the Hanford Nuclear Site. A primary goal of the surveys was to demonstrate the feasibility of using a landstreamer to image the top of the basalt. We were able to collect an average of 606 m of profile line at 2 m station spacing per day, for a total of 12,722 m. The survey successfully imaged the top of the basalt and demonstrated that a landstreamer with gimbaled geophones can provide quality seismic data in this area. We found that the top of the basalt ranged in depth from 30 to 100 m deep, and it displays a rugose character caused by faults and erosion from turbulent flood waters of ice-age floods originating from Glacial Lake Missoula or from later ancestral Columbia River flooding. Erosional features present in the basalt might provide an avenue for mixing of water between the supra-basalt and the basalt-confined aquifers, and faults might provide pathways for groundwater flow. You do not have access to this content, please speak to your institutional administrator if you feel you should have access.

Withholding Tax on Total Return Equity Swaps: Navigating in Turbulent Waters

This article gives historical perspective as to how U.S. tax authorities struggled to fit a sophisticated financial product like Total Return Equity Swaps into the existing tax “cubbyholes”, and suggests that the current methodology used by U.S. tax authorities to analyze sophisticated financial products needs to be reconsidered.