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A large share of the primary energy is consumed to provide space heating. Geothermal energy offers a regenerative alternative. For reasons of efficiency and environmental protection, it is important to ensure the system integrity of a borehole heat exchanger (BHE). Previous investigations have focused on the individual components of the BHE or on the grout and pipe systems’ integrity. This study focused on the analysis of the hydraulic system integrity of the complete subsoil–grout–pipe system as well as possible thermally induced changes. For this purpose, a pilot-scale experiment was built to test a 1-m section of a typical BHE under in situ pressure, hydraulic and temperature conditions. During the tests the hydraulic system permeability of the soil and the BHE was measured continuously and separately from each other. In addition, the temperature monitoring array was installed in a 50-cm cross-sectional area. Significant temperature-related fluctuations in the sealing performance could be observed. Hydraulic conductivity limits required by VDI 4640-2 (Thermal use of the underground—ground source heat pump systems, 2019) were exceeded without frost action. The succeeding application of freeze–thaw cycles further enhances the system permeability. The study shows that the thermally induced effects on the system integrity of the BHE are larger and more significant than the subsequent frost-induced effects. The hydrophobic character of the high-density polyethylene (PE-HD) pipes as well as its high coefficient of thermal expansion seem to be the main points of weakness in the system. Optimization research should focus on the interface connection between grout and pipe, whereby hydrophilic pipe materials such as stainless steel or aluminum should also be considered as well as manipulation of the pipe surface properties of PE-HD.

In November 2020, the IRS and Treasury doubled down by taking a different approach, asserting the taxpayers expenses were not deductible because the expenses were eligible for reimbursement.3 That is, rather than treating the PPP loan as a loan (despite the issuance by a bank, with required repayment if criteria were not met), the PPP was instead a reimbursement program. A business would also be eligible if it suffered a drop of more than 50% of gross receipts (within the meaning of section 448(c) of the Internal Revenue Code).5 We normally view a receipt as an actual collection, however, the reference to section 448(c) led us to the section 448 regulations to clarify that the term gross receipts is viewed based on the taxpayer's accounting method (i.e., cash or accrual). Even though the 2005 temporary regulations specifically include tax-exempt income in gross receipts, Treasury and the IRS divined congressional intent, providing guidance to exclude the forgiveness of the PPP loan if the safe harbor of the revenue procedure is utilized9 Simplicity and the ERC-Wages The ERC implicates (at least) two sets of attribution rules and a list of related parties. The aggregation rules have been utilized for years for various purposes, the most familiar including testing for discrimination for fringe benefits,11 aggregation of gross receipts in the determination of a small business,12 and the determination of a related taxpayer for purposes of various tax credits.13 Subsection 52(a) refers to IRC § 1563 for the controlled group of corporations.

As in other Alpine regions, in the Zillertal Alps drinking water is typically supplied privately or in cooperatives from nearby springs. An amendment of the Austrian Drinking Water Ordinance led to a reduction of the aresenic limit from 50 µg/l to 10 µg/l, so that some waters no longer meet the requirements. Measures have to be taken to ensure compliance. In this study, the Zemmbach catchment (225 km²) is examined to provide a reference-date measurement. Within eleven days, 135 springs and creeks were sampled to identify appropriate springs, especially regarding concentrations of arsenic and uranium. Locally the groundwater quality differs due to various changes of petrographic units. The applied concept is appropriate to provide a broad overview of the groundwater quality and to identify springs suitable to augment drinking water supply. However, these springs have to be observed more intensively over a longer period of time, in order to ultimately assess their suitability as a drinking water source.

Rental real estate and passive activities Without getting too deep into the labyrinth (there is no intention here of writing a book), rental real estate activities default to passive status.1 Real estate rentals are also subject to recharacterization rules for passive activity purposes.2 For example, the net rental income from substantially nondepreciable property is characterized as nonpassive, but a net loss is passive.3 The result is the same if the owner of the rental real estate leases the property to a trade or business in which the taxpayer materially participates.4 The recharacterization rules apply regardless of whether the rental activity rises to the level of a trade or business (more on that later). Rental real estate and the net investment income tax The net investment income tax applies to the lesser of net investment income or the excess of adjusted gross income (AGI) over the threshold amount.10 The term \"net investment income\" is a misnomer. A taxpayer is not subject to the net investment income tax (i.e., the income is not net investment income) on rental real estate activities if they are not passive.12 Rental real estate activity income may be recharacterized as nonpassive if it is from a significant participation activity (an activity in which the taxpayer participates for over 100 hours but does not materially participate), property rented incidental to a development activity, or a self-rental.13 If so recharacterized under the passive activity rules, the income is also not net investment income for purposes of the net investment income tax. A taxpayer is engaged in a trade or business when the taxpayer is involved in the activity with continuity and regularity, and the taxpayer's primary purpose for engaging in the activity is for income or profit.19 The rental of property is not, as a matter of law, precluded from being a trade or business, and under appropriate circumstances, the long-standing definition of \"trade or business\" includes the rental of even one property.20 The rental of real estate is a trade or business if the taxpayer-lessor engages in regular and continuous activity in relation to the property,21 even if the taxpayer rents only a single piece of real estate.22 The owner may carry on these activities through an agent as well as personally.

The legislation allows most businesses with average annual gross receipts, or AAGR, no greater than $25 million to use the cash method of accounting.2 It also exempts these businesses from some of the more onerous recordkeeping requirements, including: * The uniform capitalization rules of Sec. 263A;3 * Specific inventory accounting rules;4 * The business interest expense limitation rules of Sec. 163(j);5 and * Certain long-term contracting requirements under Sec. 460.6 However, these valuable exemptions are unavailable to a business that meets the relevant definition of a tax shelter, regardless of whether it satisfies the $25 million gross receipts test. The Joint Committee on Taxation published a report in 2017 that compares the annual gross receipts of businesses of various types (C corporation, S corporation, partnership, and sole proprietorship).14 Although 4.36% of C corporations reported gross receipts on their 2014 tax returns in excess of $10 million, the numbers for S corporations and partnerships were substantially fewer at 2.35% and 1.20%, respectively.15 The number of sole proprietorships reporting gross receipts in excess of $10 million was negligible. The definition of 'tax shelter' If a taxpayer is found to be a tax shelter, it is not allowed to compute taxable income under the cash receipts and disbursements method of accounting.18 Nor may it rely on the other tax simplifications for small businesses mentioned above. Because of this, the tax shelter definition is important. According to Letter Ruling 9321047, the \"classification as a syndicate and its prohibition from using the cash method of accounting depends on how its members arc classified and how its losses are allocated.

We introduce Procgen Benchmark, a suite of 16 procedurally generated game-like environments designed to benchmark both sample efficiency and generalization in reinforcement learning. We believe that the community will benefit from increased access to high quality training environments, and we provide detailed experimental protocols for using this benchmark. We empirically demonstrate that diverse environment distributions are essential to adequately train and evaluate RL agents, thereby motivating the extensive use of procedural content generation. We then use this benchmark to investigate the effects of scaling model size, finding that larger models significantly improve both sample efficiency and generalization.

Zusammenfassung Wie in anderen Alpenregionen auch, erfolgt die Trinkwasserversorgung in den Zillertaler Alpen vorwiegend privat oder in Genossenschaften aus nahe gelegenen Quellen, typischerweise mit kleinen Einzugsgebieten. Durch eine Veränderung der österreichischen Trinkwasserverordnung wurde der Arsengrenzwert von 50 µg/l auf 10 µg/l herabgesetzt, wodurch Quellwässer vielerorts nicht mehr den Anforderungen genügen. Es sind Maßnahmen zur Einhaltung des Grenzwertes herbeizuführen. In dieser Studie werden Ergebnisse der Stichtagsbeprobung des Zemmbacheinzugsgebietes auf einer Gesamtfläche von 225 km 2 vorgestellt. Binnen elf Tagen wurden 135 Quellen und Oberflächengewässer beprobt. Die Untersuchungen dienten der Auswahl alternativer Quellen anhand trinkwasserrechtlich relevanter Kennwerte mit Fokus auf Arsen und Uran. In einigen Teilen des Untersuchungsgebietes variiert die Grundwasserbeschaffenheit aufgrund diverser Wechsel petrographischer Einheiten kleinräumig. Das angewendete Konzept einer Stichtagsbeprobung ist gut dazu geeignet, einen weiträumigen Überblick der Grundwasserbeschaffenheit zu erhalten und Quellen zur Ergänzung oder Ersetzung der lokalen Wasserversorgung zu identifizieren. Diese Quellen sind intensiver zu beobachten, um letztlich mittels Zeitreihen Entscheidungen zu treffen.

Erratum zu: Grundwasser – Zeitschrift der Fachsektion Hydrogeologie 2019 https://doi.org/10.1007/s00767-019-00436-9 Im Beitrag, S. 2 im Abschnitt Untersuchungsgebiet, 1. Absatz wurde mg/l anstatt µg/l angegeben. Korrekt muss es heißen: … (maximal 23,6 µg/l As und 22,7 µg/l U, siehe Abb. 3) …

Practitioners should always check Sec. 38 before concluding that a credit is not within Subpart B or D. The taxpayer's regular tax liability allocable to all passive activities for the tax year is the excess of the taxpayer's regular tax liability9 for that tax year over the amount of the taxpayer's regular tax liability determined by reducing the taxpayer's taxable income for the year by the excess of the taxpayer's passive activity gross income over the taxpayer's passive activity deductions.10 Consequently, a taxpayer can only take a passive activity credit against tax attributable to passive activity income. An enumerated credit arising from the activity appears to remain passive. Since the activity is not a former passive activity, the credit is not freed up from suspension. Without tax liability from passive income, the passive credit is not available to offset the tax.15 The analysis above appears to be confirmed by reading Form 8582-CR, Passive Activity Credit Limitations, in which the taxpayer calculates allowable passive credits, allowing the credits only against tax on passive income shown on Form 8582, Passive Activity Loss Limitations. EXECUTIVE SUMMARY * Tax credits of an activity may be suspended under the passive activity credit rules if the activity is treated as a passive activity for a taxpayer. * Under the passive activity credit rules, a credit subject to the rules will be fully or partially suspended if the sum of a taxpayer's credits subject to the passive activity rules are greater than the taxpayer's regular tax liability allocable to all the taxpayer's passive activities. * Although the income of a passive significant participation activity is recharacterized as nonpassive, the activity itself will continue to be treated as passive, and credits generated by the activity will be passive activity credits, which cannot be used to offset the tax on the recharacterized income. * Depending on a taxpayer's situation, reducing participation in a significant participation activity to make the activity's income passive or increasing participation to material participation levels so the activity is no longer a passive activity may help the taxpayer accelerate the use of suspended passive activity credits. * Passive activity credits are not affected by the disposition of the activity and remain suspended until they can offset tax attributable to passive activity income.

In the sale of a C corporation, goodwill in many cases is the property of a shareholder rather than of the corporation. The Tax Court has found this to be the case where the success of the corporation depended on the shareholder's ability and reputation and there was no noncompete agreement between the shareholder and the corporation. The shareholder must recognize the income from the sale of the goodwill as capital gain. However, a related question arises: Is that gain subject to the net investment income tax under Section 1411? Many commentators seem to assume that it is. However, a careful analysis of the net investment income tax and passive activity loss regulations should lead to the opposite conclusion for most sales of personal goodwill. This article looks at the circumstances under which goodwill can be considered a shareholder's property and why the income from the sale of goodwill developed by the personal efforts of the individual should not be subject to the net investment income tax.