Indirect tax

An indirect tax (such as sales tax, per unit tax, value added tax (VAT), or goods and services tax (GST), excise, consumption tax, tariff) is a tax that is levied upon goods and services before they reach the customer who ultimately pays the indirect tax as a part of market price of the good or service purchased. Alternatively, if the entity who pays taxes to the tax collecting authority does not suffer a corresponding reduction in income, i.e., impact and tax incidence are not on the same entity meaning that tax can be shifted or passed on, then the tax is indirect.
An indirect tax is collected by an intermediary (such as a retail store) from the person (such as the consumer) who pays the tax included in the price of a purchased good. The intermediary later files a tax return and forwards the tax proceeds to government with the return. In this sense, the term indirect tax is contrasted with a direct tax, which is collected directly by government from the persons (legal or natural) on whom it is imposed. Some commentators have argued that "a direct tax is one that cannot be charged by the taxpayer to someone else, whereas an indirect tax can be."
Indirect taxes constitute a significant proportion of total tax revenue raised by the government. Data published by OECD show that the average indirect tax share of total tax revenue for all member countries in 2018 was 32.7% with standard deviation 7.9%. The member country with the highest share was Chile with 53.2% and at the other end was USA with 17.6%. The general trend in direct vs indirect tax ratio in total tax revenue over past decades in developed countries shows an increase in direct tax share of total tax revenue. Although this trend is also observed in developing countries, the trend is less pronounced there than in developed countries.
Indirect taxes have several uses, the most prominent one (same as for direct taxes) is to raise government revenue. Sales tax and value added tax (VAT) play the major role in this, with VAT being more commonly used around the world. The distinction between these two taxes is that sales tax is paid by the customer at the moment of purchase of the final good or service, whereas VAT is a multistage tax imposed on goods and services that is collected in parts at each stage of production and distribution of goods and services in proportion to the value added by each taxpaying entity.
Apart from the role in raising government revenue, indirect taxes, in the form of tariffs and import duties, are also used to regulate quantity of imports and exports flowing in and out of the country. In case of imports, by tariff imposition the government protects domestic producers from foreign producers that may have lower production costs, and thus are able to sell their goods and services at lower prices, driving domestic producers out of the market. After tariff imposition, imported goods become more expensive for domestic consumers, hence domestic producers are better-off than before tariff imposition.
Furthermore, indirect taxes in the form of excise taxes are used to reduce the consumption of goods and services that create negative externalities. For instance, an excise tax imposed on a pack of cigarettes increases the price of cigarettes, which leads to decreased consumption of cigarettes, which leads to the reduction of health conditions caused by smoking and second-hand smoking. Moreover, the tax discourages the youth from taking up smoking as they have quite elastic price elasticity of cigarette demand.
The concept of Value Added Tax (VAT) as an indirect tax was the brainchild of a German industrialist, Dr. Wilhelm von Siemens in 1918. A hundred years later, the tax which was devised to be efficient and relatively simple to collect and enforce is, together with Goods and Services Tax (GST), now in place in over 140 countries globally.
Characteristics of indirect taxes.
Tax incidence of indirect taxes is not clear, in fact, statutory (legal) incidence in most cases tells us nothing about economic (final) incidence. The incidence of indirect tax imposed on a good or service depends on price elasticity of demand (PED) and price elasticity of supply (PES) of a concerned good or service. In case the good has an elastic demand and inelastic supply, the tax burden falls mainly on the producer of the good, whereas the burden of the good with an inelastic demand and elastic supply falls mainly on consumers. The only case when the burden of indirect tax falls totally on consumers, i.e., statutory and economic incidence are the same, is when the supply of a good is perfectly elastic and its demand is perfectly inelastic, which is, however, a very rare case. The shifting of the tax incidence may be both intentional and unintentional. In fact, economic subject may shift the tax burden to other economic subject by changing their market behavior. For example, tax imposed on the output of a firm’s good may lead to higher consumer prices, reduced wages paid to firm’s employees and reduced returns to firm’s owners and shareholders or reduced supply of the good on the market, or any combination of mentioned consequences.
Indirect taxes have substantial regressive impact on the distribution of income since indirect tax is usually imposed on goods and services irrespective of consumer’s income. In practice, the effective indirect tax rate is higher for individuals with lower income, meaning that an individual with lower income spends on a good or service higher proportion of their income than an individual with higher income. For example, consider a good with $100 sales tax imposed on it. An individual with the income $10,000 pays 1% of their income as the tax while a poorer individual with income $5,000 pays 2% of their income. Moreover, the regressivity of indirect tax system impacts the total progressivity of tax systems of countries given the importance of indirect tax revenues in government budget and the degree of regressivity of indirect tax system, which ranges among countries. Furthermore, the extent of regressive nature of an indirect tax depends on the type of indirect tax.  Empirical evidence suggests that excise taxes are in general more regressive than VAT. This could be attributed to the fact that excise taxes are levied on goods such as alcohol, tobacco, and these goods comprise a higher share of budgets among poorer households, while at the same time, poorer households are likely to consume goods with reduced VAT rates given that in some countries there is a VAT deduction on necessities such as food and medicine. As a result of the regressive nature of indirect taxes and the fact that they tend to be unresponsive to economic conditions, they cannot act as automatic stabilizers within the economy, unlike some of direct taxes.
Indirect taxes, specifically excise taxes, are attractive because they have a corrective nature. Such taxes raise revenue and at the same time they correct a market failure through increasing price of the good and thus decreasing its consumption. Therefore, less revenue needs to be raised through other taxes, which could be more distortionary, to cover the market failure. The economy benefits from the reduced extent of the negative externality and from lower reliance on other taxes that distort production. Apart from generating revenue and reducing the consumption of goods creating negative externalities, excise taxes can be tailored to impose tax burdens on those who cause the negative externality or those who benefit from government services. Examples are petrol tax, argued to be user fees for the government provided roads, and tobacco tax, imposed on smokers who through smoking create a negative externality of consumption. The design of such excise tax determines the consequences. Two main types of excise taxes are specific tax (tax imposed as fixed amount of money per unit) and ad valorem tax (tax imposed as the percentage of the price of a good). Specific and ad valorem taxes have identical consequences in competitive markets apart from differences in compliance and enforcement. As for imperfectly competitive markets, such as the cigarette market, ad valorem taxes are arguably better as they automatically produce higher per-unit taxes when firms reduce production to increase prices, whereas specific taxes need to be readjusted in this case, which is administratively and legislatively difficult process.
Moreover, indirect taxes are usually associated with relatively lower administrative costs than direct taxes. In general, the administrative costs of tax system are determined by its complexity, and most costs associated with administering come from special provisions such as deductibility of certain categories of expenditures, which is typical for direct taxes such as personal and corporate income taxes. The indirect evidence may be drawn from the fact that developing countries have significantly lower direct-to-indirect tax ratio than developed countries given that choice of tax mix in developing countries is mainly based on administration and capacity issues. Developing countries used to heavily rely on trade taxes collected at centralized ports of entry into the country, which is associated with the relatively low cost of collection and enforcement. The relative importance of trade taxes in developing countries in recent years is on decrease due to trade liberalization, however, the drop of importance of indirect taxes in developing countries was partially offset by increases in the relative importance of domestic consumption taxes such as VAT. Empirical evidence suggests that income levels are associated with reduced reliance on expenditure taxes, countries with larger government size are more likely to rely more on direct taxes and that the countries prefer to use taxes for which there are relatively large tax bases available. At the same time, developing countries tend to have lower government size, which restricts them to have a more complex and efficient tax system, lower income levels in the country, and it is more practical for them to focus on taxing larger tax bases due to its lower administrative costs. Furthermore, different types of indirect taxes differ in terms of administrative costs. VAT, in which the large proportion of the revenue is generated by large corporations responsible for large part of the economy’s values added has lower administrative costs than sales tax, in which the tax is imposed only at the final level in countless retail outlets of various sizes. Moreover, VAT is associated with relatively low administrative costs due to lower enforcement and collection costs due to the fact that VAT is collected throughout the production chain, which allows for the comparison of reported sales on each stage of the vertical production chain by the fiscal authority.
"Indirect tax" in the U.S. constitutional law sense.
The term "indirect tax" has a different meaning in the context of American Constitutional law: see direct tax and excise tax in the United States. In the United States, the federal income tax has been, since its inception on July 1, 1862, an indirect tax (more specifically an excise). During the 1940s, its application grew from a historical average of about 8% to around 90% of the population paying it as a measure to support the war effort.
The difference between direct tax and indirect tax.
The main criterion to distinguish between direct tax and indirect tax is whether the tax burden can be passed on. Indirect taxes are levied on goods and services. They only indirectly target the public. With the circulation of goods, most of the turnover tax will be passed on to subsequent links. It is in this sense that the economist Mueller said: “(Indirect tax) ostensibly imposes this kind of tax on someone, but in fact, that person can be compensated by damaging the interests of another person." Below, income tax and property tax, this kind of tax that cannot or is inconvenient for taxpayers to transfer the tax burden to others, are all typical direct taxes. Income tax includes personal income tax, corporate income tax, etc., and property tax includes property tax and inheritance tax. , Social security tax, etc.
It is not difficult to see that the taxpayer of direct tax is also the actual payer of the tax. To a large extent, a direct tax is a direct deprivation of citizens' property rights, and its collection can more arouse citizens' feeling of "tax pain". Taxpayers of indirect taxes are not taxpayers. Consumers who pay for indirect taxes are often placed in the status of "vegetative" in the law and are not sensitive to their own taxpayer's rights, and the feeling of "tax pain" is not strong. . This largely explains why the actual burden on farmers is still not light after China’s abolition of the agricultural tax. This is due to the increase in the cost of fertilizers and seeds. Farmers still have to pay for them, which has become the ultimate “negative tax” in the national tax system. People" are related. Regarding this issue, Western countries do not include tax in the price of goods but list the tax separately on the consumption bill. The price is the price, and the tax is the tax so that consumers can clearly be taxpayers.
The development of indirect taxes.
After the financial crisis, the governments of many countries still have strong funding needs. Whether it is financing the economic stimulus plan or gradually making up for the funding gap caused by the economic shock, indirect taxes have proven to be the first choice for income generation for many years and will continue to be so in the future. The large number of advocates who promote the shift from direct to indirect taxes can explain this trend, such as the International Monetary Fund (IMF), the Organization for Economic Cooperation and Development (OECD), and the European Commission. Some international studies have shown that value-added tax (VAT) has the least impact on economic growth, while corporate income tax has a negative impact on economic growth.
Another important reason for this sustained development is that in the context of international tax competition and economic weakness, it is not allowed to levy more and more corporate or personal income taxes. Indirect taxes, by definition, are borne by consumers, do not depend on profits, and are limited by the economic situation. Indirect taxes mainly generate more income in three ways:
According to the OECD's "Consumption Tax Trends, 2014", as of January 1, 2014, 164 countries in the world have levied value-added tax, of which Africa accounts for 46 countries, North America 1 and Central America and the Caribbean There are 12 in South America, 28 in Asia, 51 in Europe, and 8 in Oceania. As a result, only a few countries have levied a retail tax, which is a tax on a single link of goods and services borne by the final consumer.
In addition, the number of countries with "value-added tax" continues to grow, especially in emerging economies. On January 1, 2005, the Bahamas introduced a value-added tax. On April 1, 2015, Malaysia introduced a value-added tax to replace the existing sales and service tax. Egypt introduced a value-added tax law that will replace the existing general sales tax system. The tax reform plan entrusted by the Puerto Rico government to the research team will increase general fund revenue, simplify overall compliance and promote economic growth.
In countries that have already levied value-added tax/consumption tax, the average tax rate is increasing year by year, and this trend will continue. This upward trend is particularly significant in Europe and OECD countries, where the average standard value-added rate has reached 21.6% (EU member states) and 19.2% (OECD member states), while only 19.5% and 17.5% before 2008 economic crisis. Average.
Compared with previous years, European tax rates started to be surprisingly stable in 2015, although tax rates are still at a high level. Iceland reduced the standard tax rate from 25.5% to 24% (and the tax rebate rate increased from 7% to 11%), but some countries’ tax rates are increasing. Luxembourg’s standard tax rate has increased from 15% to 17%. The main reason for the increase. And more countries will join the ranks of raising tax rates: Italy is considering raising tax rates, and Portugal may follow suit.
The increase in higher indirect tax revenue is due to the truly global trend of increased consumption taxes. Tobacco excise taxes will increase in many countries, including Denmark, Ecuador, Finland, Ghana, Malta, Ireland, the Netherlands, Norway, Russia, Slovenia, Sweden, and Tanzania. The countries that have increased the consumption tax on alcohol are Lithuania, Norway, and Tanzania. In addition, mineral oil consumption taxes have increased in China, Estonia, Finland, Gambia, Hungary, Norway, and Russia. Not only is the tax rate increasing, but the government is also levying new taxes. For example, a relatively new trend is the collection of excise taxes on health-related products (non-alcoholic beverages and tobacco products), such as fast food taxes and sugar taxes on “unhealthy” foods. In many countries, expenditures on health and welfare may be linked to taxes, and as the population ages and the pressure to increase government spending in these areas increases, these taxes may become more common.
In addition, the government is also trying to increase taxation on financial transactions, although this is not an international practice. Some countries have also strengthened the supervision and management of the banking industry. In Europe, the preferred method is to impose a financial transaction tax. France introduced a financial transaction tax in August 2012, and Hungary implemented a 1% tax on paid services in January 2013. Italy subsequently imposed taxes on equity transfer derivatives and high-frequency trading in March 2013. However, 11 EU countries that will impose daily transaction taxes on stock and bond exchanges and derivative contract schemes (FTT) have further delayed their taxation. The 11 member states participating in the meeting have agreed to impose this tax in January 2016.
Indirect taxes are adapting to new economic conditions.
One of the characteristics of indirect taxes is that they are very closely related to economic conditions. Indirect taxes are usually subject to economic transactions, such as the sale of goods or the provision of labor services. Once the nature of these transactions or the method of transactions changes, indirect taxes will quickly be greatly affected.
To give an example that clearly undermines the indirect tax system is the rise of e-commerce. E-commerce can be defined as products or services that are traded through the Internet. Since the 1990s, the Internet has been widely used, and the world has become a "click" world. This change has had a huge impact on consumer behavior, because it allows consumers to buy all kinds of goods online without leaving home, and then allows them to purchase from abroad those already expropriated in China. Value-added tax services are used to avoid tax burdens. In the past few years, e-commerce has been the fastest growing in many countries.
Such an important development means a huge change: it will cause distortions in competition between local and foreign suppliers and will have a major impact on VAT revenue, especially when it involves sales to end consumers (ie B2C transactions). The international community responded quickly to this new reality, and in 1998, the OECD member states unanimously adopted the "Ottawa Taxation Framework Conditions" on e-commerce taxation:
However, in most countries, there is no complete and unified plan for the collection of e-commerce taxes. In recent years, governments all over the world have realized that incomplete legislation has brought a huge loss of fiscal revenue, and have begun to actively implement new rules.
Recent examples of how the digital economy affects value-added tax laws include the EU’s changes to the new regulations promulgated on January 1, 2015, for B2C electronic service providers. These services are subject to tax management at the consumer's residence or residence (not the supplier's residence), which requires foreign service providers to register and pay VAT in the EU member states to which the consumer belongs. But not only can this change be felt in the EU, but similar rules may also soon be introduced in Albania, Angola, Japan, South Africa, and South Korea.
The United States faces special challenges in this regard. For the United States, most of its own consumption tax is the sale of single-rate products. In order to keep up with the rapid development of the Internet economy, many state and federal governments have successfully enacted legislation requiring "remote sellers" (suppliers who sell taxable goods to customers in other states) to collect and remit taxes across states. The most recent trend is to apply sales and use taxes to trade intangible assets (remote access to electronic delivery software, digital music, and books). Similarly, the processing of designated IT services, including data processing, "cloud computing" and "information services", continues to face the scrutiny of national legislators. Many states have announced that they are considering expanding sales to cover a wider range of service transactions. Most notably, California lawmakers announced at the end of 2014 that they would tax almost all service transactions in the country (except for healthcare and education services) to offset the reduced personal income tax rate. Of course, if you want these measures to succeed, it depends on the situation.


Eowa of Mercia

Eowa (or Eawa) (d. 642) was a son of the Mercian king Pybba and a brother of the Mercian king Penda; he was possibly King of Northern Mercia, as the 8th-century "Historia Brittonum" reports that he was co-ruler with his brother Penda.
Battle of Maserfield.
"Historia Brittonum", Chapter 65, notes that "[Penda] fought the battle of Cocboy, in which fell Eawa, son of Pybba, his brother, king of the Mercians, and Oswald, king of the North-men, and he gained the victory by diabolical agency." The "Annales Cambriae" (644) mentions "[t]he battle of Cogfry in which Oswald king of the Northmen and Eawa king of the Mercians fell."
These two sources state that Eowa was a king of the Mercians himself at the time of the Battle of Maserfield (or Cogwy), in which he was killed, on August 5 of what was probably the year 642. The later Mercian kings Æthelbald, Offa and Ecgfrith were descended from Eowa; the period of their rule began in 716 following the death of Penda's grandson Ceolred and ended with Ecgfrith's death in December 796.
It was in the battle of Maserfield that Oswald of Northumbria was defeated and killed by the Mercians under Penda. Eowa also died in that battle, although little is known about this. It has been suggested that Eowa may have been a co-ruler of the Mercians alongside Penda, or possibly even superior in status to Penda at this time (if so, this could explain why the "Historia Brittonum" seems to date Penda's reign from the battle of Maserfield), and that he may have been subject to Oswald and fighting as his ally in the battle. It is possible that it was customary among the Mercians until this time for there to be more than one king, and Penda and Eowa may have ruled over the southern and northern Mercians respectively.
Neither Bede, in his "Ecclesiastical History of the English People", nor the "Anglo-Saxon Chronicle" mentions Eowa's participation or death at Maserfield, or his previously being a Mercian king, but the "Chronicle" later mentions him when tracing the descent of Æthelbald and Offa.
Nicholas Brooks wrote that, if Eowa is considered to have ruled during the period between roughly 635 and Maserfield, this could account for an obscure recorded Welsh raid into Mercian territory, during which it is said that no mercy was shown to "book-holding monks". Brooks noted that if Eowa was a Northumbrian puppet, there would be the possibility that Oswald may have made moves to promote Christianity in Mercia at this time, thus accounting for the presence of monks in what was still a pagan kingdom. Since Penda is known to history as an ally of the Welsh, this along with the presence of monks makes it seem unlikely that the raid could have taken place during his rule.
Descendants.
The "Anglo-Saxon Chronicle" records the lineage of two Mercian kings of Eowa's blood, Æthelbald and Offa:
"Aethelbald was Alweo's offspring, Alweo Eawa's offspring, Eawa Pybba's offspring...", Later, it gives the lineage of Eowa's great-great-grandson Offa, who ruled from 757 to 796 and was descended from Osmod rather than Eowa's other son Alweo: "That Offa was Thingfrith's offspring, Thingfrith Eanwulf's offspring, Eanwulf Osmod's offspring, Osmod Eawa's offspring, Eawa Pybba's offspring, Pybba Creoda's offspring, Creoda Cynewald's offspring, Cynewald Cnebba's offspring, Cnebba Icel's offspring, Icel Eomer's offspring, Eomer Angeltheow's offspring, Angeltheow Offa's offspring, Offa Wermund's offspring, Wermund Wihtlaeg's offspring, Wihtlaeg Woden's offspring".


Harry D. Yates

Harry Douglas Yates (July 21, 1903 in Buffalo, Erie County, New York – October 9, 1996 in Menands, Albany County, New York) was an American banker and politician from New York. He was for a short time Acting New York State Comptroller in 1941.
Life.
Yates was the son of Mary Theresa Duffy (1874-1956) and Harry Yates (1870-1956).He graduated B.S. from Hamilton College in 1925.
On April 27, 1932, he was appointed First Deputy Comptroller by Morris S. Tremaine. After Tremaine's death in office on October 12, 1941, Yates acted as Comptroller for a week until Governor Herbert H. Lehman appointed American Laborite Joseph V. O'Leary to fill the vacancy. Yates continued in office as First Deputy under O'Leary until November 1942 when he resigned to enter the U.S. Army and help with the war effort during World War II. He joined the Adjutant General's Corps stationed at Washington, D.C.. While on leave in 1944, he married Anita Pohndorff (1914-1991) of Saratoga, New York.
He left the Army as a captain, and after his return to Albany, New York, managed the Dutch Village Apartments in Menands, NY, and became President of the Albany Home Savings Bank.
He was a trustee of Hamilton College, the Albany Institute of History and Art, and Siena College. He was awarded an honorary L.H.D. from Siena College in 1972, and the Distinguished Service Award from the Episcopal Bishop of Albany in 1973.


Lawrence of Ilok

Lawrence of Ilok (, ; c. August 1459 – c. June 1524) was a Croatian-Hungarian nobleman, a member of the Iločki noble family, very wealthy and powerful in the Kingdom of Hungary-Croatia. He held the title "Voivode (Duke) of Ilok" and Voivode of Bosnia, and was during his life Ban of Macsó (1477–1492), Ban of Belgrade (1511–1513), member of the Royal Chamber Council (around 1516) and judge royal (1517–1524).
Biography.
Ancestry and family.
He was born between 6 August and 3 September 1459. The son of Nicholas of Ilok, Ban (viceroy) of Croatia, Voivode of Transylvania as well as titular King of Bosnia, and his second wife Dorothy Széchy of Gornja Lendava, Lawrence was born most probably in Ilok, the family seat, as a descendant of once lower-nobility-family from Dubica County in Lower Slavonia (an area that corresponds to modern northwestern Bosnia, on the right bank of the Sava river), whose first known member was Gug (in some sources "Göge"), who had lived in the 13th century. He was the third in a row to have carried the name Lawrence in his family; his great-great-great-grandfather was Lawrence I, called "Slaven" (English: "The Slav", Latin: "Sclavus"), Hungarian: "Tót"), who died in 1349, and the nephew of the latter was named Lawrence II (floruit 1325–1367).
Having remained the sole male descendant of his father, he inherited large estates with a lot of castles and fortified towns after his father's death in 1477. He succeeded in retaining most of the power and reputation of the family. From the two of his marriages there was just one issue, a son, who died at an early age. His first wife was Catherine Pongrác of Dengeleg, a daughter of John Pongrác, Voivode of Transylvania, who died around 1510. Then he married Magdalene Bakóci, who survived him and later married Ladislaus More of Csula.
Political orientation.
First mentioned in documents as early as 1460, then in his father's will in 1471, Lawrence of Ilok inherited in 1477 not only the whole property of Nicholas of Ilok, but a continuity of the latter's political orientation as well. This became obvious after the death of King Matthias Corvinus in 1490, as he, like the majority of Croatian nobility, strongly supported Matthias' illegitimate son John Corvinus to be a new king. Since Hungarian nobility preferred and finally elected Vladislaus II Jagiellon, he did not accept it but joined the supporters of the third candidate to the throne, Maximilian I of Austria, who started a war against Jagiellon.
It was a long-term relationship between the Habsburgs and the House of Ilok, because his father Nicholas had been a supporter of Frederick III much before Lawrence was born, and even became godfather of Frederick's new-born son Maximilian in 1459.
In the war between the two pretenders to the crown, which lasted from 1490 to 1491 and ended with the signing of the Peace of Pressburg, he was firmly on the Habsburg's side. At the end of hostilities, he still did not recognize the Treaty and Jagiellon as the new ruling king. When Jagiellon's army attacked him in 1494, he was forced to withdraw and flee, losing almost all of his estates. Then finally he changed his mind, and, with help from some influential king's advisors, managed to reach the king in an audience in Pécs in order to apologize to him and to reconcile. It was only in 1496 that his estates were returned to him, under condition of being confiscated after his death without leaving a male heir.
Mature age and final years.
Having received his properties back, he tried, like his father before him, to maintain them and to build and renovate fortifications, due to every-day increasing Ottoman danger. The most exposed of all of his lands were those in northeastern Bosnia and in the southern part of Macsó banate.
He supported the Catholic Church and was its patron. He financed the erection of new sacral buildings and the renewal of the old ones. Especially he focused his efforts on urging the pope to canonize John Capistrano, since this catholic martyr died in Ilok and was buried there in the local franciscan church, but with no success.
After reconciliation with the king, he performed several high state duties, e.g. Ban of Belgrade (1511–1513), member of the Royal Chamber Council (around 1516) and judge royal (1517–1524).
Lawrence of Ilok died between 23 May and 15 June 1524, and was buried in the Franciscan church of St. John of Capistrano in his town Ilok, next to the graves of his first wife Catherine and his father Nicholas. Although slightly damaged, his gravestone is rather well preserved and is being open to the public today.


District Voluntary Force

District Voluntary Force (DVF) is a special constabulary unit of the Odisha Police. They are primarily used in anti-Maoist operations. It was formed in 2009.
Organisation.
Odisha has 500 personnel under the DVF. They do not wear special lapels or badges. 40% are recruited from former Special Operation Group (SOG) agents, as they retire after 35; and rest from the local police who speak the local dialects and know the terrain. They work in groups of 8–10. Some of them gather information and other carry out operations. They don't require the approval of Superintendent of Police for operations, unlike the SOG. However for bigger operations, SOG is sent to avoid casualties, as DVF lacks the training. DVF agents have 30% higher salary than the local police.
In January 2011, the state government announced that they would increase the number of DVF personnel. The number of district with DVF units would be increased from 11 to 17.
Notable operations and incidents.
In early March 2014, a DVF team killed two Maoist in Koraput district. In mid-May 2014, Purna Huluka (alias Khatru) was shot dead by a DVF team in Koraput district. He had a bounty of on his head.
In mid-September 2014, a DVF team killed a wanted Maoist leader, Erra Madkami (alias Sundhi Dalei), in Malkangiri district. Madkami had a bounty on his head. In late December 2014, acting on a tip-off a joint team of DVF and SOG raided a Maoist hideout and captured two Maoists in Sambalpur district.


Life assurance premium relief

Life assurance premium relief (LAPR) was a United Kingdom taxation rule.
It is a tax break that may apply to life assurance policies that provide for a capital sum to be paid on death, where the policy commenced prior to 14 March 1984.
It is due in respect of premiums payable under any such life assurance policy issued in respect of an insurance made before 20 March 1968. For such policies entered into between 20 March 1968 and 13 March 1984, the policy must also be a qualifying policy. "Qualifying policy" is defined in Schedule 15 of the Income and Corporation Taxes Act 1988.
HMRC planned to abolish LAPR from 6 April 2015


Swarup Singh of Udaipur

Swarup Singh (or Sarup Singh) (8 January 1815 – 17 November 1861) was the Maharana of Udaipur State (r. 1842–1861). He was the biological son of Maharaj Shivdan Singh of Bagore branch of the family, but was adopted by Maharana Sardar Singh. His reign spanned the Indian Rebellion of 1857 although he remained on the sidelines, as a party to the 1818 treaty with the British, signed by Maharaja Bhim Singh. He died in 1861 four years later after the Indian rebellion.


Battle of Picacho Pass

The Battle of Picacho Pass, also known as the Battle of Picacho Peak, was an engagement of the American Civil War on April 15, 1862. The action occurred around Picacho Peak, northwest of Tucson, Arizona. It was fought between a Union cavalry patrol from California and a party of Confederate pickets from Tucson, and marks the westernmost battle of the American Civil War.
Background.
After a Confederate force of about 120 cavalrymen arrived at Tucson from Texas on February 28, 1862, they proclaimed Tucson the capital of the western district of the Confederate Arizona Territory, which comprised what is now southern Arizona and southern New Mexico. Mesilla, near Las Cruces, was declared the territorial capital and seat of the eastern district of the territory. The property of Tucson Unionists was confiscated and they were jailed or driven out of town. Confederates hoped a flood of sympathizers in southern California would join them and give the Confederacy an outlet on the Pacific Ocean, but this never happened. California Unionists were eager to prevent this, and 2,000 Union volunteers from California, known as the California Column and led by Colonel James Henry Carleton, moved east to Fort Yuma, California, and by May 1862 had driven the small Confederate force back into Texas.
Like most of the Civil War era engagements in Arizona (Dragoon Springs, Stanwix Station and Apache Pass) Picacho Pass occurred near remount stations along the former Butterfield Overland Stagecoach route, which opened in 1859 and ceased operations when the war began. This skirmish occurred about a mile northwest of Picacho Pass Station.
Battle.
Twelve Union cavalry troopers and one scout (reported to be mountain man Pauline Weaver but in reality Tucson resident John W. Jones), commanded by Lieutenant James Barrett of the 1st California Cavalry, were conducting a sweep of the Picacho Peak area, looking for Confederates reported to be nearby. The Arizona Confederates were commanded by Sergeant Henry Holmes. Barrett was under orders not to engage them, but to wait for the main column to come up. However, "Lt. Barrett acting alone rather than in concert, surprised the Rebels and should have captured them without firing a shot, if the thing had been conducted properly." Instead, in midafternoon the lieutenant "led his men into the thicket single file without dismounting them. The first fire from the enemy emptied four saddles, when the enemy retired farther into the dense thicket and had time to reload. ... Barrett followed them, calling on his men to follow him." Three of the Confederates surrendered. Barrett secured one of the prisoners and had just remounted his horse when a bullet struck him in the neck, killing him. Fierce and confused fighting continued among the mesquite and arroyos for 90 minutes, with two more Union fatalities and three troopers wounded. Exhausted and leaderless, the Californians broke off the fight and the Arizona Rangers, minus three who surrendered, mounted and carried warning of the approaching Union army to Tucson. Barrett's disobedience of orders had cost him his life and lost any chance of a Union surprise attack on Tucson.
The Union troops retreated to the Pima Indian Villages and hastily built Fort Barrett (named for the fallen officer) at White's Mill, waiting to gather resources to continue the advance. However, with no Confederate reinforcements available, Captain Sherod Hunter and his men withdrew as soon as the column again advanced. The Union troops entered Tucson without any opposition.
The bodies of the two Union enlisted men killed at Picacho (George Johnson and William S Leonard) were later removed to the National Cemetery at the Presidio of San Francisco in San Francisco, California. However, Lieutenant Barrett's grave, near the present railroad tracks, remains undisturbed and unmarked. Union reports claimed that two Confederates were wounded in the fight, but Captain Hunter in his official report mentioned no Confederate casualties other than the three men captured.
Aftermath.
Before this engagement a Confederate cavalry patrol had advanced as far west as Stanwix Station, where it was burning the hay stored there when it was attacked by a patrol of the California Column. The Confederates had been burning hay stored at the stage stations in order to delay the Union advance from California. About the same time as the skirmish at Picacho Peak, a larger force of Confederates was thwarted in its attempt to advance northward from Santa Fe, New Mexico, in the Battle of Glorieta Pass. By July the Confederates had retreated to Texas, though pro-Confederate militia units operated in some areas until mid-1863. The following year, the Union organized its own territory of Arizona, dividing New Mexico along the state's current north–south border, extending control southward from the provisional capital of Prescott. Although the encounter at Picacho Pass was only a minor event in the Civil War, it can be considered the high-water mark of the Confederate West.
Re-enactment.
Every March, Picacho Peak State Park hosts a re-enactment of the Civil War battles of Arizona and New Mexico, including the battle of Picacho Pass. The re-enactments now have grown so large that many more participants tend to be involved than took part in the actual engagements, and include infantry units and artillery as well as cavalry. The 2015 re-enactment, which was held March 22 and 23, also included re-enactments of the Battle of Valverde and the Battle of Glorieta Pass, both of which took place in relatively nearby New Mexico. The skirmish site and the remains of the Butterfield station are listed on the National Register of Historic Places.


West Lynn Creamery, Inc. v. Healy

West Lynn Creamery, Inc. v. Healy, 512 U.S. 186 (1994), was a United States Supreme Court case.
Background.
Facts.
After milk prices plummeted, the Massachusetts Department of Food and Agriculture issued a pricing order that taxed all the raw milk sold by milk dealers to Massachusetts retailers and dispersed the revenue as a subsidy to Massachusetts dairy farmers. The order, which was designed to aid only Massachusetts milk producers, required dealers to pay into a fund monthly payments that were determined by subtracting from $ 15 the monthly federal blend price for 100 pounds of raw milk. Although approximately two-thirds of such milk was produced outside Massachusetts, the entire fund was distributed monthly to Massachusetts dairy farmers according to each farmer's proportionate contribution to the state's total production of raw milk.
Two licensed Massachusetts milk dealers, who purchased raw milk outside of Massachusetts but did business in Massachusetts,
refused to make the payments required under the pricing order, and Massachusetts commenced license revocation proceedings against the dealers.
The dealers then sought an injunction against enforcement of the order on the ground that the order violated the Federal Constitution's commerce clause (Art I, 8, cl 3).
Procedural history.
The Superior Court of Suffolk County, Massachusetts, denied relief, and a Massachusetts official conditionally revoked the dealers' licenses.
The Supreme Judicial Court of Massachusetts, expressing the view that the local benefits provided to the Massachusetts dairy industry by the pricing order outweighed any incidental burden on interstate commerce, affirmed the Superior Court judgment.
Opinion of the Court.
On certiorari, the United States Supreme Court reversed. Justice Stevens wrote for the majority, joined by Justices O'Connor, Kennedy, Souter, and Ginsburg.
He determined that the pricing order violated the commerce clause, where (1) the avowed purpose and undisputed effect of the order were to enable higher-cost Massachusetts dairy farmers to compete with lower-cost dairy farmers in other states; (2) the tax was effectively imposed on only out-of-state products; (3) the order would almost certainly cause local goods to constitute a larger share, and goods with an out-of-state source to constitute a smaller share, of the total sales in the market; (4) by distributing monies directly to Massachusetts dairy farmers, the order insured that Massachusetts producers would benefit; (5) the order was unconstitutional even if (a) the tax on milk sales and the subsidy to Massachusetts dairy farmers would each be constitutional standing alone, (b) the dealers who paid the tax were not competitors of the farmers who received disbursements from the fund, and (c) the costs of the program imposed under the order were borne by only Massachusetts dealers and consumers; and (6) the order's burden on commerce could not be justified by the local benefit preserving the Massachusetts dairy industry.
Negative Commerce Clause jurisprudence had long forbidden state tariffs because they discriminated against interstate commerce by burdening out-of-state competitors to the benefit of in-state businesses. The Court explained that a state could not use its legitimate powers to tax and to subsidize state businesses to effect the illegitimate aim of imposing what was in effect a tariff. The Court held that a nondiscriminatory tax had been coupled with a legitimate subsidy to create an effect that nonetheless violated the Commerce Clause.
Thus, the Court reversed the state supreme court's order, which had upheld a pricing order by the Massachusetts Department of Food and Agriculture to tax milk produced out-of-state and to distribute the proceeds to in-state dairy farmers. The Court held that the order violated the negative Commerce Clause because, like a tariff, it benefitted in-state economic interests by burdening out-of-state competitors, such as the milk buyers.
Concurrence.
Justice Scalia, concurred, joined by Justice Thomas.
He argued that (1) a self-executing negative commerce clause should be enforced against a state law that (a) facially discriminates against interstate commerce, or (b) is indistinguishable from a type of law previously held unconstitutional by the Supreme Court; and (2) applying this approach, or at least the second part of it, the pricing order was invalid.
Dissent.
Chief Justice Rehnquist dissented, joined by Justice Blackmun.
He stated that no decided case supported the court's conclusion that the negative commerce clause prohibits a state from using money that it has lawfully obtained through a neutral tax on milk dealers and distributing the money as a subsidy to dairy farmers.


Stephen II, Ban of Bosnia

Stephen II () was the Bosnian Ban from 1314, but in reality from 1322 to 1353 together with his brother, Vladislav Kotromanić in 1326–1353. He was the son of Bosnian Ban Stephen I Kotromanić and Elizabeth, sister of King Stefan Vladislav II. Throughout his reign in the fourteenth century, Stephen ruled the lands from Sava to the Adriatic and from Cetina to Drina. He was a member of the Kotromanić dynasty. He was buried in his Franciscan church in Mile, near Visoko, Bosnia.
Early life.
A member of the Kotromanić, there are sources that state that Stephen II was a "patarene" (see Bosnian Church).
When his father died in 1314 and Croatian Ban Mladen II Šubić emerged as "Count of Zadar, Princeps of Dalmatia and Second Bosnian Ban", Stephen's mother Elizabeth took him and his siblings and fled with them into exile to the Republic of Dubrovnik. Mladen was not popular in Bosnia and had fought bloody but losing wars against the Serbian Kingdom (under Stephen Uroš II Milutin), and the Venetians (to whom he lost Zadar in 1313), along with numerous internal opponents of his regime. Mladen came to the idea to impose Stephen Kotromanić as his vassal in Bosnia, for he was sure that he would be well accepted in Bosnia. The Šubić, vengeful enemies of the House of Kotromanić now became their protectors. Mladen decided to keep Stephen II under his firm grip and to use him to eradicate the Bosnian Church, so he arranged a marriage between Stephen and a Princess from the family of the Count Meinhard of Ortenburg that ruled in Carniola. The Pope was against the marriage since both families were of same German roots, but it would give Stephen certain advantages, so he convinced the Pope to allow it.
Reign.
Ascent.
Ban of Croatia, Mladen II, member of the Šubić noble family, became Ban of Bosnia in 1305, following his uncle, who was appointed Ban of Bosnia by his brother Paul I and was killed in fighting "Bosnian heretics" in 1304. Paul I referred to himself as Lord of all of Bosnia in a charter from 1305, but it is doubtful that he held all Bosnia at any time.
Until 1319 Mladen's II army had already entirely retreated from Bosnia, as he had found himself stuck in numerous troubles and conflicts with revolting cities in Dalmatia. This disorder greatly helped Stephen II as he gained influence and the chance to rule on his own and build up his realm opened up, all the while his supreme liege, the Hungarian king Charles I Robert, had plans which required Ban's help. Charles I went on a campaign to eradicate the Croatian magnates in order to become the sole ruler of the realm. He isolated Matthew III Csák and destroyed the Kőszegi family. The time had come for the Šubićs. Near the end of 1321, he ordered Stephen II to act from Bosnia supported by Ban Ivan Babonić from Slavonia, encircling and isolating Croatia. Stephen II now fell under King Charles Robert's direct command. Due to the fact that he wanted to get revenge and get rid of the Šubićs, this was useful to him for the time being, since he could then rule Bosnia uninterrupted without incursions from Dalmatia, and practically entirely by himself as Charles I would be too far away to watch his every move. Besides that, he also got a chance to expand his influence in Croatia. The decisive battle happened near Mladen's capital Skradin in 1322, where he was defeated decisively. Mladen II fell back to Klis Fortress and waited for Charles I to come, blindly believing that he would somehow retain his power because of Šubić's loyal service during King's ascension to tron. However, Charles I came to Knin and invited Mladen to meet him there where he was immediately arrested and sent to a dungeon in Hungary where he died.
Early reign and other marriages.
Immediately after the death of Serbian King Stefan Uroš II Milutin in 1321, he had no problem in acquiring his lands of Usora and Soli, which he fully incorporated in 1324. He helped his uncle Vladislav of Syrmia to regain all Serbia, but after the fall of Ostrvica at Rudnik at the hands of Stefan Dečanski, there was no more point in supporting him during the struggles for the Serbian throne, so he took Usora and Soli for himself. The hostility caused by this between Bosnia and Serbia would lead to Stephen II Kotromanić's war against Dečanski several years later.
When his uncle Vladislav died, he gained some parts of his realm of Syrmia. After this, Stephen II spent the first years of his reign in relative peace. He gave numerous privileges to the local nobility to increase popularity. One of the most famous was the edict in which he gave some "župe") to Prince Vukoslav. In the edicts he refers to his brother Vladislav with the title "Prince of Bosnia" sharing equal rule with him since 1326, although Stephen had, being Ban, the real rule.
In 1323 Hungarian King Charles Robert wanted to increase influence over Ban Stephen II Kotromanić. He offered Stephen the hand of his wife's distant relative, Elizabeth of Kuyavia, daughter of Duke Kazimierz III of Gniewków and received from the King as a gift with the marriage the lands to the west formerly held by Mladen I Šubić Bribirski and Usora and Soli in the north formerly held by Stephen Dragutin and his son, Vladislav II of the Nemanjić. The marriage was legalized by 1339. Up to 1339 Stephen was still married to the daughter of the Bulgarian tsar and had been previously married to a countess of Ortenburg.
Conflicts in Dalmatia.
The Hungarian king Charles I Robert had asked Stephen II again, around 1323, to join the new Ban of Slavonia Nikola Omodijev and launch a joint offensive against Nelipić in Croatia. Nikola's expedition eventually failed, but it did rise up Juraj II Šubić (brother of Mladen II Šubić) against Nelipić, and, eventually, Bosnian Ban Stephen II himself. The movement wanted to return the Šubić to power in Croatia with Juraj II on the throne. When an all-out war broke out between the armies of Prince Ivan Nelipić and Juraj II Šubić in the Summer of 1324, Ban Stephen II contributed considerable support to the Šubićs, without involving his forces into clashes. It turn out to be good move, because the Šubić's party was massacred near Knin and Juraj II Šubić himself was captured by Prince Nelipac. Stephen II had attempted to liberate Juraj II from imprisonment, but without success.
Ivan Nelipić immediately pushed the fight against Ban Stephen II, and managed to capture city of Visuća, but Stephen's shrewd politics and willingness to bestow his nobility with privileges had paid off, as Vuk of Vukoslavić family had helped him to retake the city. Although Stephen's military ambitions were only relatively successful he continued to wage war against the enemies of the Šubić. His target was the city of Trogir which was one of the major supporters of Nelipić's campaigning. Stephen adopted a harsh tactic. His forces raided Caravans from Trogir, which eventually forced its denizens to humbly sign a peace and addressed him as the "high and mighty lord Stephen free ruler and master of Bosnia, Usora and Soli and many other places and Prince of the Hum". It is because of this that Stephen started a conflict with the Republic of Ragusa regarding trade. Stephen was shown as a very tough negotiator and the negotiations finally ended in 1326.
After seeing that Ban Nikola Omodejev was unable to weaken the position of Nelipić, Hungarian King Charles I deposed him. The new man for the job was one of his most trusted men, Ban Mikac Mihaljević. Ban Mikac advanced toward Croatia in the summer of 1325. Bosnian Ban Stephen II sent several squadrons to assist him in his offensive. In 1326, after taking Babonić family cities Mikac advanced deeper into Croatia, where he meet Stephen's reinforcements. The expedition eventually had little success, so Mikac sent a portion of his army to Bihać which would serve as defence against Nelipić's possible counterattacks and retreated to Hungary.
Ban Stephen II gained territories, expending his realm to the coast by annexing space between mouths of the Cetina and the Neretva rivers, and all in between Bosnia main proper and the coast, namely vast expanses of karst poljes of Livanjsko, Duvanjsko and Glamočko, which will from that point on be known as Završje (also "Western Sides", ), until territorial reconfiguration under Ottomans. Ban also annexed towns and forts of Imotski, Livno, Duvno, Glamoč, Grahovo. In just a year from this point Stephen II will turn to Zahumlje and annex it for Bosnian realm as well.
Conflict with Serbia.
By 1326 Ban Stephen II attacked Serbia in a military alliance with the Republic of Ragusa and conquered Zahumlje (or Hum), gaining more of Adriatic Sea coast, from mouth of the Neretva to Konavle, with areas significant Orthodox population under Archbishopric of Ohrid and mixed Orthodox and Catholic population in coastal areas and around Ston. He also expanded into Završje, including the fields of Glamoč, Duvno and Livno.
These parts of the province of Hum, that Ban conquered and annexed for Bosnia, were ruled by the Serbian vassalage family the Branivojevićs and their overlord Crep, Stefan Dečanski's viceroy for Trebinje and coastal areas around Ston, whom Branivojević attacked and killed. The King Stefan had no desire to defend this family and their lands from Ban Stephen's forces claiming their past sins, but in reality he assessed Bosnians to strong for his forces. Bosnia controlled the coast from the border with Ragusa across Neretva to Omiš. Ban Stephen himself killed two members of the Branivojević, while Branko Branivojević fled to Serbia and sought help from King Stefan and then headed to Ragusa, from where he proceeded to Ston. Ban Stephen pursued the chase of Branko, but eventually the Ragusan forces caught the last of the four brothers from the Branivojević. The Bosnian titles included "Lord of the Hum Land" ever after. Ban Stephen became the ruler of all the lands from Cetina to Neretva with the exception of Omiš which was taken by the Hungarians.
In 1329, Ban Stephen II Kotromanić pushed another military attempt into Serbia, assaulting Lord Vitomir of Trebinje and Konavli, but the main portion of his force was defeated by the Young King Dušan who commanded the forces of King Stefan Dečanski at Priboj. The Ban's horse was killed in the battle, and he would have lost his life if his vassal Vuk had not given him his own horse. By doing so, Vuk sacrificed his own life, and was killed by the Serbian troops in open battle. Thus the Ban managed to add Nevesinje and Zagorje to his realm.
Although the Zahumljans mostly accepted the Ban's rule, some resisted, like Petar Toljenović who ruled the "Seaside" from his capital in Popovo; he was the grandson of the famous Andrija, Prince of Hum. Petar raised a rebellion, wishing either more autonomy or total independence and the eventual restoration of the conquered territories to Serbia. He lost a battle against Ban Stephen II and was imprisoned and put in irons. Stephen had him thrown with his horse off a cliff. Peter survived for a full hour after the fall.
The Ban's vassal that governed Hum started to raid Ragusa's trade routes, which worsened Bosnian-Ragusan relations that were very high during the conquest of Hum. To make matters worse, he (Ban's vassal) asked Ragusa to pay him the old traditional mogorish tax that it traditionally paid to the Hum and Serbian rulers and even asked it to recognize his supreme rule. The Republic of Ragusa refused outright.
Religious tensions in Bosnia.
The Pope was enraged by the religious tensions that grew in Bosnia, installed Fabian of the Franciscan Order as the Inquisitor in Slavonia and gave him the task of rooting out heresy in Bosnia. The Pope requested Stephen II's full assistance. In 1327 the Dominicans and Franciscans argued over who would be granted the task of burning the heretics. Although Fabian eventually took over the leadership over the movement, he utterly failed. Then the Pope wrote to the Hungarian King for a military intervention in Bosnia.
In 1334, the Bosnian Bishop Peter died, and a huge dispute began over his successor. Hungarian King Charles Robert managed to replace his supporter, but it would take until 1336 for the final dispute to be resolved in the Catholic Church's favour.
Pope Benedict XII lost all patience and eventually accepted the offer of Prince Nelipac of Croatia in 1337, who not only wanted to restore Bosnia under Croatian control, but also desired personal revenge on Stephen II Kotromanić for the past troubles that he had caused him. The still powerful Croatian Šubićs family protested Nelipac's decision. An arranged marriage was made between Bosnian Ban Stephen II's brother, Vladislav and the sister of Ban of Croatia Mladen III Šubić, Jelena Šubić in 1338 in Klis Fortress. Mladen III Šubić's wife was Jelena Nemanjić, sister of the Serbian King Stefan Dušan, so this created a strong dynastic alliance of three families: the Kotromanić, the Šubić and the Nemanjić that strictly opposed Prince Nelipac's reign. The first to fall to Nelipac's hand were the Šubićs who were, despite constant help from Stephen II, were forced to sign a peace treaty with Nelipac and compensate him for the war. Charles Robert did not watch easily as his subjected lands were being war-torn. He was preparing to move to Croatia and depose Nelipac. Stephen II seized the opportunity and pushed against Nelipac, talking some of his lands for himself.
Soon, Ban Stephen II would finally stop the constant threat of the Western Crusades to the Bogumil population of Bosnia. In 1339, during Franciscan General Gerard's stay at the Hungarian Court of King Charles Robert, Gerard paid a visit to the Bosnian Ban to negotiate an arranged prosecution of Bosnia's heretics. At first, Stephen II thought that it was time to bow to the Roman Catholic Church; but he realised that the neighboring Orthodox Christians might stand up to him if he moved against the Bogumils, their allies. In addition, Serbia wanted a reason to involve itself in a conflict, for its King desired revenge for the losses in the Bosnian war against the Serbs, so Ban Stephen abandoned the thought. Nevertheless, Stephen's diplomatic efforts convinced the Pope that he was a loyal Catholic in February 1340, once again saving Bosnia.
After the final peace between the Bosnian Ban and the Papacy, the Catholic Church started to grow in influence rapidly throughout Bosnia in 1340-43. The Roman Catholic monks had constructed numerous monasteries in Usora and Hum and baptised a large number of Bosnia's heretics on their way to Ston in the Republic of Ragusa. This process eventually brought on the demise of the Bosnian Church that held supremacy over the religious life in Bosnia.
Changes in the throne.
In 1342, Hungarian King Charles Robert died and so did Stephen II's past ally, Mikac of Slavonia in 1343. This gave rise to a new idea. The opportunity arose to detach Bosnia from the Kingdom of Hungary and for Ban Stephen II to rule it independently. He immediately sought help from Hungary's greatest foe, the Republic of Venice. In the summer of 1343 he sent an emissary to Venice, proposing an alliance. The Venetians wanted to act only if victory was certain, so they wanted another member in their alliance; their traditional ally, Serbia. The Serbian King was, unfortunately for the Venetians, busy with other matters. Venice was just waging war against Prince Nelipac, so it only agreed to arm and help build up Bosnia's military, but begged Stephen II not to move against Hungary without it. It became evident that the Venetians only wanted to push Ban Stephen II against Nelipac for additional support.
In 1344, Nelipac himself unexpectedly died, which prompted Hungarian nobility to ordered the new Slavonian Ban to seize Knin from Nelipac's widow Vladislava and her son Ivan. She attempted to negotiate help from Venice, but the Croatian nobility cut off the negotiations. The Hungarian King became impatient, so he commanded Ban Nikola to move to Knin immediately and ordered Ban Stephen II of Bosnia to send help at once. Ban Stephen came leading his forces. A large 10,000 strong Army was amassed near Knin, and this was only the first wave as the main part of the Army was arriving headed by the Hungarian King himself. This time Princess Vladislava Nelipić had no choice but to accept demands. The Hungarian King planned the shape of his coastal territories in the new order that he would create. He annexed several cities from the Nelipić family of Croatia, but left them the two largest until Stephen II gave the Cetina region back. Bosnian ban Stephen II swore an Oath to respect the treaty in front of his "Twelve Knights", whom he had just formed out of the most valiant and experienced of the Bosnian nobility to assist him in his reign. In the middle of 1345 the new order was ratified in Bihać. The Hungarian King subsequently issued a proclamation in Zagreb accepting Ban Stephen II as a member of his family and returned with his 30,000 men to Hungary before attempting to reconquer the coastal cities taken by the Venetians.
Upon the numerous changes, Zadar switched side from Venice back to Hungary, but their letter missed the Hungarian King during his stay in Bihać, so they had to seek alternative allies whom they found in the Šubić and the Serbian King Stefan Dušan. When it became evident that the Venetians were going to attack, Zadar asked Hungary directly to intervene. The Hungarian King ordered Ban Stephen II and Ban Nikola of Slavonia to move with their forces in assistance. The two Bans moved with their 10,000 man Army to Zadar, only to find out that the Venetians had constructed an improvised wooden fortification with 28 "bastidas" (towers), huge enough to man the entire Venetian army. Deciding not to move against the Venetians, the Bans accepted a bribe of 1,000 florins each, although Zadar had accused them of treason.
The Hungarian King was amassing forces for a new strike against the Venetian positions, but both parties had elected the new Serbian Emperor Stefan Dušan to assist Ban Stephen II and form a mediation party to decide a truce between the two warring sides. Eventually, all agreements failed. In the spring of 1346 the Hungarian King arrived with his vast Royal Army of 100,000 men of whom more than 30,000 were cavalry and men-at-arms and 10,000 soldiers under Ban Stephen II arrived. The Venetians had attempted to bribe several Hungarian generals, including Ban Stephen II, who gave away the positions of the Hungarian troops for a handsome sum of money, thereby earning the nickname "Devil's Student". On 1 July 1346 a fierce clash occurred, which the Hungarian side eventually won only due to numerical superiority and achieved a pyrrhic victory with more than 7,000 Hungarian troops killed in battle. The Hungarian King lost trust in Ban Stephen II and, losing confidence as well, returned to Hungary.
Ban Stephen II played Venice and Hungary against each other, slowly ruling Bosnia more and more independently and soon initiated a conspiracy with some members of the Croatian and Hungarian nobility against his Hungarian liege. In 1346 Zadar finally returned to Venice, and the Hungarian King, seeing that he had lost the war, made peace in 1348. Ban of Croatia Mladen II Šubić was greatly opposed to Stephen II's policy, accusing him of treason and the relations between the two Bans worsened ever afterwards. Bosnian Ban Stephen II's relations with Venice started to improve, as the Bosnian Bishop Peregreen was a notable Venetian member of the Franciscan Order.
Continued conflict with Serbia.
The Serbian Emperor Stefan Dušan was constantly demanding that Ban Stephen II Kotromanić return the Hum area to the Nemanjić dynasty, but Stephen II always refused.
Ban Stepen's Bosnia was weaker than the Serbian Empire, so he asked Venice, as a mutual ally, to act as a mediator. Eventually the Serbian Emperor accepted a three-year non-aggression pact because he was busy with his conflicts with the Byzantine Empire. The Bosnian Ban immediately proceeded with war preparations and went to construct a fortress in Hum, near the Neretva river. He also attempted to convince the Venetians to give him naval support in the case of war with the Tsar. The Venetians discouraged him from building a fort, but he constructed it anyway. The distant wars of Tsar Stefan Dušan gave Stephen II Kotromanić the chance to move first. In the Christmas of 1349 Bosnia's Ban moved quickly, proceeding all the way across Konavli which he raided heavily until he reached the Bay of Kotor. Trebinje, Gacko, and Rudine were razed during his military operations. Venice attempted to make another peace between the warring sides, but the Serbian emperor agreed only to stall his counterattack a little.
In October 1350, Tsar Stefan Dušan crossed the river of Drina with 50,000 cavalry and 30,000 infantry. Ban Stephen II did not have the strength to meet his army in open battle, so he decided to use a guerrilla tactic. Using timber and rock he blockaded all major roads in Bosnia and slowly withdrew his forces to forests and mountains, using impervious topography of his realm and forts to defend against advancing invader. He planned the defense of Bosnia, splitting his forces enough to defend every possible entryway into his realm. His plan soon started to break, as Dušan was able to bribe several of Ban's most trusted servants who abandoned their posts.
Losing control over the conflict, Ban Stephen II retreated with his most trusted men to the most unreachable mountains of Bosnia. He no longer knew whom he could trust, so he regularly dismissed and recruited new men to serve him. His older daughter Elizabeth hid from Dušan in Ban's court and one of Bosnia's strongest fortresses, Bobovac. Dušan's forces easily defeated the scattered Bosnian squadrons and went on a campaign to slowly conquer Bosnia. Eventually, Bobovac was besieged, but Dušan failed to seize it which will prove detrimental to success of his campaign. But he proceeded by ordering his armies to raid Bosnia. After creating a strong foothold with forces in Bosnia, Dušan sent a portion of his army on raiding quests towards Cetina and the other to Croatia towards Krka, while he returned with the rest of his troops to Serbia to resolve new conflicts that the Byzantines stirred in Macedonia.
Both failed siege of Bubovac and attempt to catch up with Ban Stephen II eventually compelled Dušan to abandon Bosnia and order his troops to retreat. Ban Stephen II therefore won the war, even though he lost most of the battles. This encouraged the Ban to refuse all suggestions from Dušan to share Hum as joint rulers. Dušan forces that remained in Hum tried to keep at least this region, however Ban Stephen II soon launched a military campaign and reconquered all the territories that he had previously lost to Dušan. The Republic of Ragusa was enraged by the war over the Hum because it greatly damaged their trade, so, backed up by the Venetian Republic, Dubrovnik suggested a peace to Dušan that would constitute a marriage between the Emperor's son King Stefan Uroš V and Stephen II's daughter Elizabeth. The peace treaty also required the giving of the Hum area to Stephen II, but as a land of the Nemanjić. Stephen II had better plans for his daughter, so he refused the agreement. Ban reasoned that a large multi-ethnic Empire ruled autocratically by one man could not succeed. Politically and militarily savvy Ban, now proved himself foresighted too, as he will soon start witnessing first traces of Dušan's Empire demise, while he regained full control over his realm, Bosnia.
Last years.
The rest of Ban's reign passed mostly in peace. The only conflict that he had was a dispute with the Republic of Venice and Dubrovnik since the Ban's men had raided their trade caravan. The Ban managed to elevate his supporter, Monk Petergreen as the new Bosnian Bishop. After 1352 Stephen II referred to himself as "Bosnia's Herzeg" (or "herceg") in resemblance of the German title. The same year he gave his sister or niece, Marija, in marriage to Count Ulrich of Helfenstein, which was sanctioned by the Hungarian King. He sent his daughter Catherine (some sources describe Catherine as the daughter of Stephen's brother Vladislav) to marry Count Hermann I of Celje, but the actual marriage happened long after Stephen II's death.
Elizabeth of Poland, the mother of the King of Hungary, wanted to arrange a marriage between her son and Stephen's daughter Elizabeth. She insisted immediately on bringing her to the Hungarian court for fosterage. Stephen was reluctant at first, but eventually dispatched Elizabeth. After three years of life at the Hungarian court, the King's mother invited Stephen to Hungary for the wedding. The Bosnian Ban became gravely ill and could not be present at the ceremony.
Stephen II Kotromanić died in September 1353. He was ceremonially buried in his own foundation, the Roman Catholic Church of Saint Nicholas of the "Little Brother" in Mile, near Visoko. He was succeeded by his underage nephew Tvrtko, son of Stephen's brother Vladislav Kotromanić, with Vladislav governing in Tvrtko's name.
Edicts.
Stephen withdrew all demands as can be seen in his edict to the Republic from 1332 in which he guaranteed future friendships between the Banate of Bosnia and the Republic of Ragusa. In the edict he called his people Bosnians ("Bošnjani").
Ban Stephen II issued several edicts to Ragusa in 1333. There were four documents. Here is an excerpt of the documents edict' copies:
Of 60 words in the excerpt:
Marriages and children.
He was married to:
According to Dominik Mandić he had at least four children.
Additional readings.
Srednjovjekovna Bosna: politički položaj bosanskih vladara do Tvrtkove krunidbe, 1377, Nada Klaić, Grafički zavod Hrvatske, Zagreb 1989


Eucleidas

Eucleidas () reigned Sparta from 227 BC to 222 BC. He was an Agiad, son of Leonidas II, in the place of the Eurypontid king.
His brother, Cleomenes III, deposed his Eurypontid colleague Archidamus V, and installed his brother as his new co-ruler.
According to Pausanias, Cleomenes poisoned Eudamidas III, his Eurypontid colleague, and shared the royal power with his brother Eucleidas.
Eucleidas was killed fighting against the Macedonians at the Battle of Sellasia (222 BC).


Felipe Pazos

Felipe Pazos Roque (September 27, 1912 – February 26, 2001) was a Cuban economist who initially supported the Cuban Revolution of Fidel Castro, but became disillusioned with the increasingly radical nature of the revolutionary government. Born in Havana, Pazos earned a doctorate from the University of Havana in 1938. He was a member of the Cuban delegation to the 1944 Bretton Woods conference. In 1946, he joined the staff of the fledgling International Monetary Fund that had been established at the Bretton Woods conference. He worked there for three years before returning to Cuba in 1950 to head the newly established National Bank of Cuba for two years at the behest of Cuban President Carlos Prío Socarrás.
After Fulgencio Batista took power in Cuba through a military coup d'état in 1952, Pazos became active in supporting the resistance against Batista. Batista's rule came under increasing assault during the 1950s, and he and the Cuban military soon found themselves fighting against a young Castro and the forces of his 26th of July Movement. At the time, Castro was waging a guerrilla campaign in the mountainous Sierra Maestra region of Cuba. Batista had declared that Castro had been killed; however, Pazos arranged for "The New York Times" reporter Herbert Matthews to come and meet Castro in February 1957. The resulting interview refuted Batista's claims, and gave Castro and his revolutionaries international attention. In July 1957, Castro convened a meeting in the Sierra Maestra between his group of rebels and pro-Capitalist representatives, including Pazos. Pazos' signature on the July 12 Sierra Manifesto was meant to help reassure the Cuban people that the revolutionaries were not radical ideologues. Pazos and his family were forced to flee Cuba soon after its release.
After Castro's victory in 1959, Pazos returned to Cuba and once again headed the National Bank of Cuba. However, he soon found himself becoming increasingly disillusioned with the new Cuban government. In April 1959, Castro and his aides, including Pazos, visited the United States. Many had suspected that the purpose of the visit was to ask for economic aid, but Castro forbade Pazos from making any such requests. Pazos privately expressed his frustrations to officials at the U.S. State Department and Treasury Department.
Pazos' confidence was further weakened when Castro ordered the arrest and imprisonment in October 1959 of Huber Matos, an anti-Communist revolutionary who had recently resigned from office. After Castro angrily denounced the United States for being complicit in the "bombing" of Havana with thousands of anti-Castro leaflets by the ex-Air Force Chief Pedro Luis Diaz Lanz, Pazos decided to resign. He tendered his resignation on October 23, 1959 to President Osvaldo Dorticós Torrado. Pazos transferred the Presidency of the National Bank of Cuba to Che Guevara on November 26, 1959 and was allowed to leave Cuba soon afterward.
Pazos ended up working at the Alliance for Progress and the Inter-American Development Bank, writing many economic articles on Latin America, before retiring in 1975 to Venezuela. He died in Puerto Ordaz. He had three sons and a daughter. His son Felipe starred alongside Spencer Tracy in the 1958 film adaptation of Ernest Hemingway's "The Old Man and the Sea".


Forward guidance

Forward guidance is a tool used by a central bank to exercise its power in monetary policy in order to influence, with their own forecasts, market expectations of future levels of interest rates.
Overview.
Communication about the likely future course of monetary policy is known as "forward guidance". Individuals and businesses will use this information in making decisions about spending and investments. Thus, forward guidance about future policy can influence financial and economic conditions today.
The strategy can be implemented in an explicit way, expressed through communication of forecasts and future intentions, sometimes known as Odyssean forward guidance. Implied forward guidance also exists, sometimes referred to as Delphic forward guidance. It is a softer and less-binding version of forward guidance to achieve similar effects. Among the main central banks, Delphic forward guidance dominates, although there are a couple of exceptions such as the US Federal Reserve, which makes quite specific but still conditional statements, and the Bank of Japan.
History.
The communication policy of the Federal Reserve Bank of the United States has evolved over time. The current policy is known as "forward guidance" but this is quite recent. In fact, starting in 1994 the decisions of scheduled meetings have been announced to the public within a few minutes of 2:15 pm Eastern Time. Prior to 1994 monetary policy decisions were not announced, and investors had to indirectly infer policy actions through the size and type of open market operations in the days following each meeting. In the current context, this could be called "reverse guidance". The policy of "forward guidance" came about in the early 2000s. This has apparently resulted in a market-timing strategy, in use since 1994, "where the S&P500 index has on average increased 49 basis points in the 24 hours before scheduled FOMC announcements. These returns do not revert in subsequent trading days and are orders of magnitude larger than those outside the 24-hour pre-FOMC window. As a result, about 80% of annual realized excess stock returns since 1994 are accounted for by the pre-FOMC announcement drift". In fact, about half of the realized excess stock market returns between January 1980 and March 2011 were earned during the "pre-FOMC" window whereas there is no evidence of pre-FOMC returns before 1980. The drift is generally not dependent on either the macro economic state, market trends or action taken by the FOMC


P. A. Pematilaka

P. A. Pematilaka was the 37th Auditor General of Sri Lanka. He was appointed on 23 October 2006, succeeding Sarath Chandrasiri Mayadunne, and held the office until 3 January 2007. He was succeeded by S. Swarnajothi.


Investment Fund for Developing Countries

Investment Fund for Developing Countries ("Investeringsfonden for Udviklingslande") (IFU), is a Development Financial Institution owned by the Government of Denmark. IFU is a self-governing, state-owned fund, whose objective is to promote economic and social development in developing countries. The Fund provides risk capital and advice to companies wanting to do business in parts of Europe, Asia, Latin America and Africa.
Investments are made on commercial terms in the form of loans and equity, with the purpose of contribution to economic and social development in the investment countries and support the attainment of the United Nations Sustainable Development Goals.
Location.
The headquarters and main offices of IFU are located at Fredericiagade 27, 1310 Copenhagen K, Denmark. The geographical coordinates of the company headquarters are:55°41'08.9"N, 12°35'24.5"E (Latitude:55.685806; Longitude:12.590139). IFU also maintains regional offices in Africa, Asia, Latin America, Central and Eastern Europe.
As of August 2020, IFU maintained regional offices in these cities: 1. Copenhagen 2. Accra 3. Ho Chi Minh 4. Kyiv 5. Lima 6. Nairobi 7. New Delhi 8. São Paulo 9. Shanghai 10. Singapore. (Near bottom of reference page).
Overview.
IFU was founded in 1967, as an independent government-owned fund offering advisory services and risk capital to companies wishing to do business in developing countries and emerging markets. In addition to investing its own money, IFU acts as a fund manager. As of August 2020, IFU had co-invested in over 1,300 companies in more tan 100 countries. The investment portfolio totals DKK:209 billion (€29.07 billion), to which IFU as contributed DKK:23 billion (€3.09 billion).
Before 31 December 2016, IFU’s involvement was tied to the participation of a Danish company or the existence of a Danish interest. That requirement was dropped in December 2016. IFU does not provide business grants or development aid. Over time the investments have returned good results to the countries hosting the investments, the Danish companies and to IFU. In the 2014 to 2019 time period, gross yields on invested share capital averaged in excess of 12 percent annually.
Ownership.
Investment Fund for Developing Countries is 100 percent owned by the government of Denmark.
Governance.
"Michael Rasmussen" serves as the chairman of the company. Effective 1 January 2019, "Torben Huss" is the chief executive officer of Investment Fund for Developing Countries.
Recent investments.
IFU is an equity investor in Lake Turkana Wind Power Station, a 310 megawatts power plant, that is Africa’s largest wind farm. It supplies approximately 15 percent of Kenya's electricity needs.
IFU owns 9.97 percent of DFCU Bank, the fifth-largest commercial bank in Uganda. The shareholding was acquired in December 2019 from the CDC Group of the United Kingdom.
In In March 2019, the Investment Fund for Developing Countries (IFU), lent KSh:1.2 billion (approx. US$11.2 million) to Sidian Bank, a Kenyan commercial bank. During the next 36 months, IFU has the option to convert a portion or all of the principal into share capital in the bank. If all the principal is converted into capital, the Fund will acquire 20 percent shareholding in the bank and gain two seats on the expanded seven-person bank board. Each of the other shareholders will be diluted proportionately.


Socialist Labor Party Hall

The Socialist Labor Party Hall at 46 Granite Street, Barre, Vermont was constructed in 1900. It was a location for debates among anarchists, socialists, and union leaders over the future direction of the labor movement in United States in the early 20th century.
Located in the former Italian section of Barre, the Socialist Labor Party Hall is a two-story flat-roofed brick structure with a gambrel-roofed single story rear hall. It is associated with Barre's rich ethnic heritage, specifically the vital Italian community that immigrated to Barre at the end of the 19th century.
The direct association of this property with the labor movement, community, and the immigration of Italians makes it one of Barre's most important buildings. It was designated a National Historic Landmark in 2000 for its association with the socialist, anarchist, and labor movements, and as the only building known to have been built by volunteer members of the Socialist Labor Party.
Architecture.
Its design reflects no particular architectural style, but its form does illustrate the building's function as an assembly hall. The exterior is simply ornamented with Barre granite details. The most important of these is a carved medallion depicting an arm bearing a hammer, the symbol of the Socialist Labor Party, and the initials SLP.
History.
The building was constructed in 1900 by volunteers of the Italian community as a meeting hall for the Socialist Labor Party, a political group dedicated to social and labor reform. The Hall provided the community with a place to meet, organize, and socialize. Dances, boxing and wrestling matches were held here. In 1901, the Co-Operative store was started in the basement to provide necessities for the community.
When the Hall opened in 1900, more than 90 percent of Barre's workers belonged to one of 15 local unions, many of them probably attended union meetings and political rallies held here. From 1900 to 1936 the building held the offices and meetings of the Granite Cutters' International Association, at the time the largest local union of granite workers in the country. Labors leaders such as Eugene Debs and Samuel Gompers are known to have visited Barre and, although unconfirmed, likely spoke at the Hall.
During textile strikes taking place in Lawrence, Massachusetts, the Italian community in Barre sheltered 35 children of those striking workers, all of whom were received at the Hall. During one political gathering in 1903, illustrating the sometimes volatile nature of political groups at this time, an argument broke out between socialists and anarchists, ending in the essentially random but fatal shooting of Elia Corti, a prominent Italian stone carver responsible for the panels on the Robert Burns Memorial statue in Barre.
In 1936, the Hall was sold and converted to a warehouse for The Washington Fruit Company and later the Vermont Pak Tomato company.
The property was listed on the National Register of Historic Places in 1998, and was designated a National Historic Landmark in 2000.
In 1995 the Hall was purchased by the Barre Historical Society, with much support, to restore it as a library, community meeting hall, and social club. The Labor Hall was flooded due to rain on July 10–11, 2007. Four feet of water flooded the basement, damaging walls, equipment, and the archived documents stored in the basement.


Christopher Waller

Christopher J. Waller is an American economist who is a member of the Federal Reserve Board of Governors. Waller was nominated to and confirmed as a member of the Board of Governors in December 2020. He was sworn-in via video conference on December 18 for a term ending January 31, 2030.
He was previously the research director of and an executive vice president at the Federal Reserve Bank of St. Louis. Waller's research has centered on monetary theory, political economy, and macroeconomic theory.
Early life and education.
Waller received a B.S. in economics from Bemidji State University in 1981, and a M.A. and Ph.D. from Washington State University in 1984 and 1985.
Career.
Waller worked at the Indiana University's Department of Economics from 1985 to 1998, where he was an associate professor, assistant professor and director of graduate studies. He was a visiting scholar at the Federal Reserve Bank of St. Louis and Washington University from 1994 to 1995. He taught economics at the University of Kentucky from 1998 to 2003 and was also a research fellow at the Center for European Integration Studies at the University of Bonn, in Germany. He was a chair of economics at the University of Notre Dame through 2009.
Waller joined the Federal Reserve Bank of St. Louis as research director in 2009. He was also executive vice president there.
In July 2019, President Donald Trump tweeted his intent to nominate Waller and Judy Shelton to serve on the Federal Reserve Board of Governors.
After hearings in February 2020, the Senate Banking Committee voted 18–7 in July 2020 to advance Waller's Fed nomination. He was confirmed in the Senate on December 3, 2020, by a vote of 48–47. He took the oath of office remotely via videoconference on December 18 from Fed Chair Jerome Powell.
Views.
Waller is known to be a monetary policy "dove", favoring expansionary policy and low interest rates. He has worked closely with the St. Louis Federal Reserve bank's president, James B. Bullard, who was a vocal supporter of lower interest rates in 2019. Waller has argued that the Fed should not raise rates at that time (in 2019), when inflation was low and private savings were high.
Waller's research has centered on monetary theory, political economy and macroeconomic theory.


Ojo de Vaca Station

Ojo de Vaca Station, was a Butterfield Overland Mail stagecoach station at Ojo de Vaca (Cow Springs), in New Mexico Territory. It was located northeast of Soldiers Farewell Station and southwest of Miembre's River Station, later Mowry City. The site is now Cow Springs Ranch located in Luna County, New Mexico, United States.
History.
Ojo de Vaca was a watering place on the old trail between Janos, Chihuahua, Mexico to the Santa Rita copper mines. When Cooke's Mormon Battalion was searching for a wagon route between the Rio Grande and California, they intercepted the old Mexican road at this spring, then followed it southward to Guadalupe Pass then westward and northward to Tucson, pioneering the route known as Cooke's Wagon Road. In 1849, Cooke's road became the major southern route of the forty-niners during the California Gold Rush and Ojo de Vaca spring was one of the reliable watering places on what became the Southern Emigrant Trail. Later Ojo de Vaca was a water station on the San Antonio-San Diego Mail Line and subsequently the Butterfield company built their stagecoach station there. It remained an important stop on this route until the long distance stagecoach lines ended in the late 19th century.


George Hobart, 3rd Earl of Buckinghamshire

George Hobart, 3rd Earl of Buckinghamshire (8 September 173114 November 1804) was a British peer, styled The Honourable George Hobart from 1733 until 1793.
Life.
Hobart was the son of John Hobart, 1st Earl of Buckinghamshire by his second wife, Elizabeth Bristow. He was educated at Westminster School.
Hobart represented the constituencies of St Ives and Bere Alston in the House of Commons from 1754 to 1761 and 1761 to 1780, respectively. He was secretary to the embassy in St Petersburg in 1762, his half-brother John Hobart, 2nd Earl of Buckinghamshire being then ambassador.
He inherited the earldom of Buckinghamshire from his half-brother, who had no surviving sons, in 1793. On 29 April 1797, he was commissioned colonel of the 3rd Regiment of Lincolnshire Militia (South Lincolnshire Supplementary Militia), becoming a colonel in the regular army when his regiment was embodied on 12 January 1799. He died in 1804 and was succeeded by his son Robert, who had already entered the House of Lords in 1798 by a writ of acceleration as Baron Hobart.
Family.
Hobart married Albinia Bertie, second daughter of Lord Vere Bertie and the heiress Ann Casey, on 16 May 1757. They had eight children:


Steward Machine Co. v. Davis

Steward Machine Company v. Davis, 301 U.S. 548 (1937), was a case in which the U.S. Supreme Court upheld the unemployment compensation provisions of the Social Security Act of 1935, which established a federal taxing structure that was designed to induce states to adopt laws for funding and payment of unemployment compensation. The decision signaled the Court's acceptance of a broad interpretation of Congressional power to influence state laws.
The primary challenges to the Act were based on the argument that it went beyond the powers granted to the federal government in the U.S. Constitution and that it involved coercion of the states that called for a surrender by the states of powers essential to their quasi-sovereign existence, in contravention of the Constitution's Tenth Amendment
Background.
In the first months of 1937, the Court handed down decisions that affirmed both federal and state prerogative to legislate regarding social welfare. The decisions were the first wave of what has become known as the constitutional revolution of 1937.
There were three additional issues that set the stage in early 1937:
Use of federal government's spending power to regulate commercial economic activity.
By 1937, it had been well established that regulatory taxes controlling commercial economic actions were within the power of the U.S. Congress. In "Hampton & Co. v. United States", the U.S. Supreme Court had held that a regulatory tax is valid even if the revenue purpose of the tax may be secondary. The Court had also held that a tax statute does not necessarily fail because it touches on activities that Congress might not otherwise regulate. In "Magnano Co. v. Hamilton", the Court had stated:
Further emphasizing the broad power of taxation, the Court in "Sonzinsky v. United States" concluded that a tax does not cease to be valid merely because it regulates, discourages, or even definitely deters the activities taxed. In that case, the Court held regarding a tax on dealers in firearms:
Expansive view of general welfare.
The Supreme Court had recently decided "United States v. Butler". The main issue presented in that case was whether certain provisions of the Agricultural Adjustment Act of 1933 conflicted with the Constitution. In the Act, a tax was imposed on processors of farm products, with proceeds to be paid to farmers who would reduce their area and crops. The intent of the Act was to increase the prices of certain farm products by decreasing the quantities produced.
The Court held that the so-called tax was not a true tax because the payments to farmers were coupled with unlawful and oppressive coercive contracts, and the proceeds were earmarked for the benefit of farmers complying with the prescribed conditions. Making the payment of a government subsidy to a farmer conditional on the reduction of his planned crops went beyond the powers of the federal government. Specifically, the Court said:
Although it struck down the Act, the Court dealt positively with expenditure of funds to advance the general welfare as specified in Section 8 of Article I of the Constitution]]. The Court stated that the issue "presents the great and the controlling question in the case." After it compared opposing expansive and restrictive interpretations of the Spending Clause, the Court decided:
The idea that Congress has authority separate and distinct from powers granted by enumeration has been controversial. The fact that the Supreme Court struck down the Act despite an expansive interpretation of the Spending Clause reflects the turmoil in its thinking at the critical time.
Economic conditions.
The nation was in the midst of the Great Depression. In its "Steward" decision, the Court noted:
The unemployment compensation provisions of the Social Security Act of 1935 established a tax on employers, but if a state established an approved unemployment compensation plan, the taxpayer could credit up to 90% of the federal tax paid to the state unemployment fund. In effect, the Act established a taxing structure, which was designed to induce states to adopt consistent laws for funding and payment of unemployment compensation.
The main controversy in "Steward" was whether the tax coerced the states and whether the tax was within the powers of Congress. Justice Benjamin N. Cardozo wrote for a sharply-divided Court, which was in the process of changing its character relative to affirmation of federal action for the general welfare:
Decision.
This was the key holding regarding the excise tax of the Act:
An important part of the rationale was the conclusion that even if the excise taxes
The arguments placed the actions of Congress within its constitutional power. The Court then established that the tax and the credit in combination were not weapons of coercion that would destroy or impair the autonomy of the states. The first step was
After it reviewed the distressed condition of the nation's economy, the Court noted:
Although it was not quoted specifically in "Steward", the relevant aspect of "Butler" addressed the constitutional powers of Congress and established that Congress has a "separate and distinct" power to tax and spend that is "not limited by the direct grants of legislative power found in the Constitution."
Directly addressing the contention that the tax is coercive, Justice Cardozo wrote:
An important issue in a tax not being coercive, which was satisfied in "Steward", was for the conduct to be both encouraged or induced accomplish a national end (general welfare) and related to the tax itself:
Finally, Cardozo explicitly noted the liberty of the states to make agreements with Congress:
Based on all the foregoing arguments, the final judgment was to affirm the lower court's decision upholding the constitutionality of the Act. The ruling upholding the Act was one of the two Social Security Cases that upheld elements of New Deal legislation in 1937.
Dissenting opinions.
The essence of the dissenting opinions was that the Social Security Act of 1935 went beyond the powers that were granted to the federal government in the Constitution. Imposing a tax that could be avoided only by contributing to a state unemployment compensation fund effectively coerced each state to make law creating such a fund.
The dissenters are sometimes known collectively as the Four Horsemen, the conservative members of the Court who opposed the New Deal agenda of President Franklin Roosevelt.
Justice McReynolds.
"That portion of the Social Security legislation here under consideration, I think, exceeds the power granted to Congress. It unduly interferes with the orderly government of the state by her own people and otherwise offends the Federal Constitution... [Article 1, Section 8] is not a substantive general power to provide for the welfare of the United States, but is a limitation on the grant of power to raise money by taxes, duties, and imposts. If it were otherwise, all the rest of the Constitution, consisting of carefully enumerated and cautiously guarded grants of specific powers, would have been useless, if not delusive... I can not find any authority in the Constitution for making the Federal Government the great almoner of public charity throughout the United States" (p. 603).
Justice Sutherland, joined by Justice Van Devanter.
"The threat implicit in the present encroachment upon the administrative functions of the states is that greater encroachments, and encroachments upon other functions, will follow."
Justice Butler.
"...the statutory scheme is repugnant to the Tenth Amendment... The Constitution grants to the United States no power to pay unemployed persons or to require the states to enact laws or to raise or disburse money for that purpose. The provisions in question, if not amounting to coercion in a legal sense, are manifestly designed and intended directly to affect state action in the respects specified. And, if valid as so employed, this 'tax and credit' device may be made effective to enable federal authorities to induce, if not indeed to compel, state enactments for any purpose within the realm of state power and generally to control state administration of state laws."
Subsequent jurisprudence.
"Steward" was part of a set of decisions in which the Supreme Court consistently upheld New Deal economic and regulatory legislation. The key role of the case was the expansion of Congressional authority to the regulation of state activity, which marked the end of Supreme Court attempts to limit Congressional powers based on advancement of the general welfare. In fact, "Butler", just the year before "Steward", had been the last case in which the Supreme Court struck down an Act of Congress as beyond the authority granted by the Spending Clause.
"Steward" marked the beginning of the recognition that Congress could use the Spending Clause, under the umbrella of general welfare, to regulate state laws by incentives and encouragement but not coercion. The federal government may induce the states, tempt them, or seduce them but not coerce them into passing legislation considered desirable to meet national needs. Before "Steward", Congress could regulate only commercial economic activity, but after "Steward", Congress could regulate the actions of state governments.
It is now common for Congress to tie grants-in-aid with requirements and restrictions upon the states, but the practice is still often controversial. In a modern case depending upon the jurisprudence of "Steward", the Court held in "South Dakota v. Dole" that Congress could influence states to raise the minimum drinking age to 21 by threatening to withhold funds for federal highways. In her dissenting opinion, Justice Sandra Day O'Connor stated:
She later approved of and quoted from the text of "Butler":