Special report on taxation. New IRS revenue procedure clarifies tax classification of limited liability companies

Although its rules are complex, the publication of Revenue Procedure 95-10 will substantially facilitate the use of LLCs in those states with statutes that permit significant flexibility in the structuring of LLCs. Previously, the only way to assure that LLCs in those states would be classified as partnerships for income tax purposes was to obtain a private letter ruling from the IRS, often resulting in lengthy delays. The new revenue procedure should provide sufficient guidance in the vast majority of cases to allow tax counsel to determine the appropriate treatment for tax purposes without having to seek an IRS private letter ruling.     

Special report on reimbursement. HCFA enacts new enforcement remedies covering nursing facilities

While the regulations are revolutionary in their use of "substantial compliance," the interpretation and application of HCFA's new remedial scheme are still uncertain, as states are given broad discretion in defining important terms and in applying and interpreting the criteria to select remedies. Further complicating the issue is the fact that some states, including California, intend to seek waivers from HCFA to substitute their own state enforcement systems for most, if not all, of the new federal system. Based upon these uncertainties, the enforcement of nursing facility standards will likely be in a state of flux for some time to come.     

From underworld to underground

In the West economically motivated crime is usually perceived as a matter for the police while the performance of the economy is a matter for the political authorities. This paper argues that the growth and evolution of the modern underground economy has made such a distinction obsolete. Not only have the frontiers between the legitimate and the criminal sectors of the economy blurred, but the distinction between the explicitly criminal and the merely informal aspects of the modern underground economy has become largely meaningless. Given the tremendous growth of underground activity, this means that the issue must now be addressed not just on the enterprise level, as a police matter, but on the level of the economy as a whole, by economic policy makers. This in fact is something that many developing countries long ago realized. The paper therefore asks whether developing countries have been any more successful in using monetary, fiscal and balance of payments policy to mitigate the adverse social and economic impact of widespread underground economic activity than have Western countries who have relied mainly on the sanction of criminal law. It concludes that both approaches are deficient in so far as they neglect the degree to which modern underground activity can no longer be seen as a manifestation of deviant economic behavior so much as a virtual economic insurgency against the status quo distribution of income and wealth and the codes of economic behavior which accompany it. However dramatic are the financial manifestations of the spread of enterprise crime, ultimately the challenge it poses must be addressed as the political and ideological level.     

From the ranch of the Tia Juana to Tijuana: a brief history of development and population on the northern border of Mexico

"Tijuana has been the most extraordinary example of the modern demographic history of the [Mexican] northern border. This article is an essay on the economic, social, and demographic development of this important urban center during this century. Its purpose is two fold. On the one hand, to understand Tijuana's general population change in light of a unique socioeconomic development in the country, which has been characterized by a close dependence on the United States as well as by the creation of several federal programs aimed [at integrating] the natural economies. On the other hand, to introduce the discussion of the Mexico-United States border region to the non-specialist in this field." (SUMMARY IN ENG)     

A. reviews: general

WARFARE IN THE LATIN EAST, 1192–1291. By CHRISTOPHER MARSHALL. (Cambridge Studies in Medieval Life and Thought, fourth series, 17.) Cambridge, Cambridge University Press, 1992. xiv, 290pp. 7 figures, 9 plates.

MINORITES RELIGIEUSES DANS L'ESPAGNE MEDIEVALE [ = Revue du Monde Musulman et de la Méditerranée, 63–4]. Aix‐en‐Provence, Edisud, 1992. 292 pp. 150FF.

THE TRANSMISSION OF KNOWLEDGE IN MEDIEVAL CAIRO. By JONATHAN BERKEY. Princeton, Princeton University Press, 1992. x, 238pp. $39.50.

PRAGMATISM IN THE AGE OF JIHAD: THE PRECOLONIAL STATE OF BUNDU. By MICHAEL A. GOMEZ. Cambridge, Cambridge University Press, 1992. xiii, 252 pp. £35.00.

THE CHURCH OF THE EAST AND THE CHURCH OF ENGLAND. A HISTORY OF THE ARCHBISHOP OF CANTERBURY'S ASSYRIAN MISSION. By J.F. COAKLEY. Oxford, Clarendon Press, 1992. £45.00.

WOMEN, ISLAM AND THE STATE. By DENIZ KANDIYOTI. London, Macmillan, 1991. 271pp. + index.

MARRIAGE ON TRIAL: A STUDY OF ISLAMIC FAMILY LAW. By ZIBA MIRHOSSEINI. (Society and Culture in Modern Middle East Series.) London, I.B. Tauris, 1993. 200 pp. + notes and index.

WOMEN IN THE MIDDLE EAST: PERCEPTIONS, REALITIES AND STRUGGLES FOR LIBERATION. Edited by HALEH AFSHAR and MARY MAYNARD. Basingstoke, Macmillan, 1993. xiv, 250pp.

WRITING WOMEN'S WORLDS: BEDOUIN STORIES. By LILA ABU‐LUGHOD. Berkeley, Los Angeles and Oxford, University of California Press, 1993. xxiii, 266 pp., bibliography. $30.00 (hb), $12.00 (pb).

NASSER'S BLESSED MOVEMENT: EGYPT'S FREE OFFICERS AND THE JULY REVOLUTION. By JOEL GORDON. Oxford, Oxford University Press, 1992. vii, 254 pp.

WAR AND PEACE IN ISRAELI POLITICS: LABOR PARTY POSITIONS ON NATIONAL SECURITY. By EFRAIM INBAR. Boulder and London, Lynne Rien‐ner, 1991. 184pp., appendices. £21.95.

TURKEY AND THE WEST: CHANGING POLITICAL AND CULTURAL IDENTITIES. Edited by METIN HEPER, AYSE ÖNCÜ and HEINZ KRAMER. London/New York, Tauris, 1993. xiv, 289 pp.

TURKEY'S NEW GEOPOLITICS: FROM THE BALKANS TO WESTERN CHINA. By GRAHAM E. FULLER and IAN O. LESSER, with PAUL B. HENZE and J.F. BROWN. Boulder and Oxford, Westview Press, 1993. xv, 197pp.

THE SOCIALIST MOVEMENT IN TURKEY, 1960–1980. By IGOR P. LIPOVSKY. Leiden, Brill, 1992. ix, 190pp. $48.75.

ISLAM IN MODERN TURKEY: RELIGION, POLITICS AND LITERATURE IN A SECULAR STATE. Edited by RICHARD TAPPER. London/New York: Tauris, 1991. v, 314 pp.

SIBAWAYH THE PHONOLOGIST: A CRITICAL STUDY OF THE PHONETIC AND PHONOLOGICAL THEORY OF SIBAWAYH AS PRESENTED IN HIS TREATISE AL‐KITAB. By A.A. AL‐NASSIR. London and New York, Kegan Paul International, 1993. xx, 130 pp.

AL‐MADKHAL ILā TAQWīM AL‐LISāN WA‐TA'LīM AL‐BAYāN. By IBN HISHāM AL‐LAKHMī. Edited by JOSÉ PÉREZ LÁZARO. (Fuentes Arábico‐Hispanas, no. 6.) Madrid, Consejo Superior de Investigaciones Científicas & Insti‐tuto de Cooperatión con el Mundo Árabe, 1990. 2 vols. 219; 599pp.     

Migratory flows in the Mediterranean Basin

Recent trends in international migration in the Mediterranean region are analyzed, with the focus on South-North migration to Europe. "This migration towards Western Europe has taken various forms, from labour force migration, in a first phase, to family reunification, and more recently, asylum requests and irregular immigration. These migratory flows must be understood within the context of a severe imbalance--demographic and economic--between the Southern and Northern banks of the Mediterranean. Europe and especially the European Union is directly confronted by this persistent migratory pressure coming from the other Mediterranean countries. Its future can only be conceived of through new and innovative forms of cooperation with its Mediterranean partners." (SUMMARY IN ENG)