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By Nicasio del Castillo

INTRODUCTION The tax structure of foreign mining investment into the United States has a significant impact on the financing and the profitability of the operation. For these reasons, it is critical for the foreign investor to develop and implement a well planned tax strategy that will enable its venture to: (1) reduce its U.S. income tax liability (2) lower U.S. withholding taxes when funds are transferred from the United States, and (3) decrease or defer home country taxation on its U.S. earnings ALTERNATIVE FORMS OF INVESTMENT A threshold business and tax consideration is the form in which the investment is to be made. The most common alternatives include: forming or acquiring a U.S. mining corporation, directly establishing a branch mining operation, or entering into a joint venture or partnership with a U.S. mining company. U.S. Corporations The most common structure through which foreign mining companies engage in business in the United States is to form a U.S. mining corporation. Forming a U.S. Corporation. If the investor decides to establish a new U.S. corporation the organization is relatively simple. No distinctions are made in the United States between "public" and "private" forms of incorporation. Minimum share capital is not usually required and share capital may consist of shares with no par value. Since corporate law is the responsibility of the individual states, the foreign investor must choose a state in which to incorporate. If appreciated mining property is transferred to a corporation solely in exchange for stock or securities in that corporation, and the transferors have control of the corporation (defined as at least 80 percent of all voting shares and at least 80 percent of all other shares) immediately after the exchange, no gain or loss will be recognized. However, if the transferors receive cash or other mining properties in addition to stock, any resulting gain may, in certain situations, be taxed to the extent of the cash and the fair market value of other property received. Acquiring an Existing U.S. Corporation. Acquiring an existing U.S. mining corporation is not as straight-forward as forming a corporation. This alternative may be accomplished through either a stock or an asset acquisition. Generally, with a stock acquisition the purchaser inherits all of the business and tax attributes of the former mining corporation. If the investor is able to acquire mining assets, however, the purchaser will usually be able to avoid any unknown or hidden liabilities that could be attached to an existing corporation. Another principal advantage in acquiring assets is that the purchase price may be directly allocated to the acquired mines or other mineral-related assets with the result that the assets' depreciable base may be increased. Assuming the domestic seller and the foreign purchaser can agree, it is generally advisable to allocate the purchase price in the sales agreement to specific individual assets. From the foreign investor's standpoint, it is preferable to allocate the purchase price to depreciable assets such as buildings and equipment versus an allocation to mineral land holdings or intangibles such as goodwill, which are generally not depreciable. It is not uncommon, however, for a seller mining company being acquired to insist for tax reasons that the investor purchase shares rather than assets. If the foreign

Jan 1, 1985

ALABAMA Anniston.-Carrington, F. G. Auburn.-Brown, R. L. Battelle.-Green, G. G. Bessemer.-Abbott, C. E. Dobbs, G. G. Ferguson, V. Birmingham.-Adams, J. H. Aldrich, T. H. Aldrich, T. H., Jr. Allen, A. W. Bonnyman, J. Bowron, J. Bush, M. W. Crawford, G. G. Crockard, F. H. Ellis, E. E. Fairbairn, C. T. Gallacher, J. Geismer, H. S.

Jan 1, 1917

PRESIDENT HORACE V. WINCHELL MINNEAPOLIS, MINN. PAST PRESIDENTS PHILIP N. MOORE ST. Louis, Mo. SIDNEY J. JENNINGS NEW YORK, N. Y. FIRST VICE-PRESIDENT A. R. LEDOUX NEW YORK, N. Y. TREASURER GEORGE D. BARRON NEW YORK, N. Y.

Jan 1, 1923

By S. W. Parr

FRom a study of sulfur with reference to its specific combination in coal, published as University of Illinois Bulletin No. 111, 1919, it is now possible to determine the various forms of this constituent with a good degree of accuracy. This fact suggests two questions: (1) Are the same analytic methods applicable to coke? (2) Is there any correlation between the forms of sulfur as it occurs in coal and the residual sulfur found in the finished coke? The answer to the second question might be helpful in answering a still further question as to what chemical route the sulfur travels during the carbonization process. While the special studies along these several lines are by no means complete, a few preliminary statements are herewith presented. They may, at least, prove suggestive of further possibilities from a continuation of research along these lines. There is no reason, chemically, why the analytic methods devised for coal should not apply to coke and a fair amount of experience in connection with such use affords confirmation of this statement. The procedure in the case of coal may be briefly outlined as follows: Combinations of sulfur as sulfate, or sulfides other than FeS2, are readily dissolved without disturbing either the pyrite sulfur or the sulfur that is in organic combination by means of dilute hydrochloric acid— 1 part of concentrated HC1 to 10 parts of water or approximately 3 per cent. acid. Digestion at 60" C. for 24 hr. insures the complete removal of the sulfur thus combined. In freshly mined coal the amount of such sulfur is very small; weathering processes, however, may very materially increase the amount of sulfate present. Sulfur in the form of iron pyrites, or marcasite, may be quantitatively removed without oxidation of the organic sulfur as follows: A dilute solution of nitric: acid is prepared having 1 part of concentrated HNO3 to 3 parts of water or with an approximate specific gravity of 1.12. The coal sample, ground to 100 mesh, is digested with this solution at room temperature for 3 or 4 days, filtered and evaporated to dryness, taken up with water, and acidified with hydrochloric acid. It is now ready for precipitation with barium chloride in the usual manner. If sulfate is present in the original sample to an appreciable amount, it should be removed by the procedure outlined above. It is not necessary here to give the methods for determining the two

Jan 1, 1920

BRANCH COUNCILS Mining Branch E R Price, Chairman (Coal) Howard A Meyerhoff (Industrial Minerals) J V Beall, Secretary Richard M Foose (Industrial Minerals) Carroll F Hardy (Coal) Frank A Hardlaw (Mining, Geology, and Geophysics) S J Swainson (Minerals Beneficiation) Philip J Shenon (Mining, Geology, and Geophysics) Grover J Holt (Minerals Beneficiation) A C Callen (Mineral Industry Education) C H. Behre, Jr. (Mineral Economics)

Jan 1, 1952

Executive A R LEDUC, Chairman ARTHUR S DWIGHT R V NORRIS EDWIN LUDLOW E L DEGOLYER Membership J V W REYNDERS, Chairman E L DEGOLYER R M RAYMOND EDGAR RICKARD W Y WESTERVELT Finance WALTER H ALDRIDGE, Chairman GALEN H CLEVENGER J V W REYNDERS Library Chairman JOHN H JANEWAY GEORGE C STONES ROBERT LINTON ALEXANDER C HUMPHRLYS, - BRADLEY STOUGHTON

Jan 1, 1923

Although copper production established a new record, lead and zinc registered gains, and iron production held steady, the mixed trend in metallic and nonmetallic mining and generally lower prices in 1961 resulted in a net decline in the total value of domestic mineral production. According to preliminary estimates from the U.S. Bureau of Mines, the value of metals produced in this country during the year was approximately $1.9 billion, a decrease of $117 million from 1960; the value of nonmetallics was about $3.7 billion, a $14 million decrease. The following report of mining and mineral developments during 1961 is based on USBM and industry sources. Aluminum Output Dips from 1960 Record Government reports indicate that the domestic primary aluminum industry produced approximately 1,880,000 tons, equivalent to 77% of this nation's capacity. This production is about 6% below the 1960 record output of 2,014,498 tons. Shipments of primary metal ingot slightly exceeded the quantity produced.

Jan 2, 1962

By John Griffen

THE distinguishing principle of the Tromp process is the use of a medium in the bath which is not stable, i.e., the solids will settle and the density of the medium increases with depth. A medium of uniform density can most easily be effected by agitation or by means which increase the viscosity of the medium. Either of these works against the sharpness of separation of coal from its impurities. The Tromp process grinds the medium solids to relative coarseness, allows them to settle downward in the bath without hindrance, and introduces horizontal currents of medium at intermediate levels between top and bottom of the bath. This prevents any accumulation of particles denser than the upper layer of the medium from which the clean coal is conveyed away or an accumulation of particles lighter than the bottom layer or medium whence the refuse is removed. In a relatively shallow bath making a two-product separation, the intermediate horizontal currents sweep these intermediate gravity materials away to be discharged with the refuse removed by the conveyor. Such a system provides a number of advantages. The gravity of separation can be changed simply by changing the density of the medium without changing particle size of medium solids or other conditions, as would be necessary with a system requiring uniform or stable density throughout the bath. Some installations in Europe separate at 1.40 sp gr on one shift, producing a superclean coal, and on the next shift reclean refuse from dry cleaning units and effect a separation at 1.80 sp gr. Medium solids may be much coarser in size consist, which reduces the viscosity of the medium and promotes its fluidity and in turn the sharpness of separation. Coarser medium solids with a more rapid settling rate are much more easily recoverable from the dilute medium rinsed from the products. The Tromp process is not limited to the use of medium solids having magnetic properties. Instal-

Jan 1, 1953

By John Griffen

THE distinguishing principle of the Tromp process is the use of a medium in the bath which is not stable, i.e., the solids will settle and the density of the medium increases with depth. A medium of uniform density can most easily be effected by agitation or by means which increase the viscosity of the medium. Either of these works against the sharpness of separation of coal from its impurities. The Tromp process grinds the medium solids to relative coarseness, allows them to settle downward in the bath without hindrance, and introduces horizontal currents of medium at intermediate levels between top and bottom of the bath. This prevents any accumulation of particles denser than the upper layer of the medium from which the clean coal is conveyed away or an accumulation of particles lighter than the bottom layer or medium whence the refuse is removed. In a relatively shallow bath making a two-product separation, the intermediate horizontal currents sweep these intermediate gravity materials away to be discharged with the refuse removed by the conveyor. Such a system provides a number of advantages. The gravity of separation can be changed simply by changing the density of the medium without changing particle size of medium solids or other conditions, as would be necessary with a system requiring uniform or stable density throughout the bath. Some installations in Europe separate at 1.40 sp gr on one shift, producing a superclean coal, and on the next shift reclean refuse from dry cleaning units and effect a separation at 1.80 sp gr. Medium solids may be much coarser in size consist, which reduces the viscosity of the medium and promotes its fluidity and in turn the sharpness of separation. Coarser medium solids with a more rapid settling rate are much more easily recoverable from the dilute medium rinsed from the products. The Tromp process is not limited to the use of medium solids having magnetic properties. Instal-

Jan 1, 1953

INDUSTRIAL MINERALS DIVISION (Nonmetallics) Established as a Division March 15, 1935 Ian Campbell, Chairman Robert C Stephenson, Eastern Vice-Chairman Allen Cole, Southeastern Vice-Chairman David P Hale, Jr, Rocky Mountain Vice-Chairman G H Waterman, Western Vice-Chairman M F Goudge, Canadian Vice-Chairman James Norton, Secretary-Treasurer Mineral Deposits Branch U S Geological Survey Washington 25, D C.

Jan 1, 1952

By G. F. Tagg

In an earlier paper1, the author described a method of interpreting earth-resistivity curves, based on the theoretical investigation of a single horizontal underlying stratum. If the four-electrode system of Wenner is employed, the resistivity in a homogeneous soil is given by the formula p = 2paR [1] where a is the electrode separation and R is the resistance of the earth between the two inner electrodes. If the earth is not perfectly homo¬geneous, the application of this formula gives an apparent specific resistance varying with the electrode separation. In the special case of the single horizontal underlying stratum, there is a surface layer of thickness h and resistivity pi and a lower layer, extend-ing to infinity, of resistivity p2. It has been shown by Lancaster-Jones2 that the apparent resistivity, obtained by an application of equation 1 is related to the true resistivities, the depth h and the electrode separation a by an expression of the form pa/p1 = 1 + 4F [2] where Pa is the apparent resistivity and F is a function (actually an infinite series), of the ratio h/a, and a reflection coefficient k = (p2 - p1)/(p2 + p1). For given values of h/a and k, the right-hand side of equation 2 can be calculated, and curves drawn showing the relationship between Pa/P1, h/a and k. Such a set of curves for the case when pi > P2 is given in Fig. 1.

Jan 1, 1937

By C. H. Samans, G. F. Tisinai, J. K. Stanley

The addition of nitrogen (0.10 to 0.20 pct) to Fe-Cr-Ni alloys of simulated commercial purity results in a real displacement of the u phase boundaries to higher chromium contents. The effect is small for the (Y + s)? boundary, but is pronounced for the (y + a +s)/(y + a) boundary. Although there is an indication of an exceptionally large shift of the n boundaries to higher chromium contents, especially in steels with nitrogen over 0.2 pct, the major portion of this apparent shift results from the fact that carbide and nitride precipitation cause "chromium impoverishment" of the matrices. The effect of combined additions of nitrogen and silicon to the Fe-Cr-Ni phase diagram is demonstrated also. Nitrogen can nullify the effect of about 1 pct Si in shifting the (y + o)/? phase boundary to lower values of chromium at all nickel levels from 8 to 20 pct. NItrogen can nullify this U-forming effect of about 2 pct Si at the 8 pct Ni level, but not at the 20 pct Ni level. The alloys studied were in both the cast and the wrought conditions. There are indications that the u phase forms more slowly in the cast alloys than in the wrought alloys if both are in the completely austenitic state. The presence of 6 ferrite in the cast alloys accelerates the formation of U. Cold working increases the rate of o formation in both cast and wrought alloys. THE major improvement in Fe-Cr-Ni austenitic alloys in recent years has been in the addition or removal of minor alloying elements to facilitate better control of corrosion resistance, sensitization, and heat resistance. One shortcoming of the austenitic Fe-Cr-Ni alloys, which never has been completely circumvented, is their propensity toward u formation. In the AISI-type 310 (25 pct Cr-20 pct Ni) and type 309 (25 pct Cr-12 pct Ni) steels, sufficient amounts of u phase can form, if service or treatment is in a suitable temperature range, to cause severe embrittlement. Also, there is a growing conviction that this phase may be contributory to some unexpected decreases in the corrosion resistance of certain of the 18 pct Cr-8 pct Ni-type steels. The present paper discusses the effect of nitrogen additions on the location of the (r+u)/d and the (y+a+u)/(y+a) phase boundaries in the ternary Fe-Cr-Ni system, for cast and wrought alloys of simulated commercial purity, and in similar alloys containing up to about 2.5 pct Si. The objective is to define compositional limits for alloys which will not be susceptible to u formation when used near 1200°F (650°C). An excellent review of the early studies of the u phase in the Fe-Cr-Ni system has been compiled by Foley.1 Rees, Burns, and Cook2 have determined a high purity phase diagram for the ternary system, whereas Nicholson, Samans, and Shortsleeve3 are- stricted themselves to a portion of the simulated commercial-purity phase diagram. Both groups of investigators show almost an identical position for the commercially significant (y+u)/y phase boundary. Further comparison of the work of the two groups indicates that, below the 8 pct Ni level, the commercial alloys have a decidedly greater propensity toward u formation than the high purity alloys. The two groups of workers agreed that both the AISI-type 310 (25 pct Cr-20 pct Ni) and the type 309 (25 pct Cr-12 pct Ni) steels are well within the (y+~) region and that the 18 pct Cr-8 pct Ni-type alloys straddle the U-forming phase boundaries. Nicholson et al.3 showed, in addition, that these boundaries shift toward lower chromium contents if greater than nominal amounts of silicon or molybdenum are added. The effect of nitrogen on the location of the s phase boundaries in the Fe-Cr-Ni system has not been known with any certainty. In 1942, an approach to this problem was made by Krainer and Leoville-Nowak,' but at that time they apparently were unaware of the slow rate of s formation in strain-free samples and aged their samples for insufficient times, e.g., 100 hr at 650°C (1200°F) and 800°C (1470°F). For this reason, it would be expected that their (y+ u) /y boundary would be shifted toward lower chromium contents (restricted ?-field) when equilibrium conditions were approximated more closely. Procedure for Studying the Alloys The alloys used were prepared in the following way: Heats of 200 lb each were melted in an induction furnace. A 5 lb portion of each heat was poured into a ladle containing an aluminum slug for de-

Jan 1, 1955

By Stanley W. Ivosevic

The South-Central Osa Peninsula produced around 30,000 kg (100,000 troy oz) of gold since prehistoric times. Gold freed by erosion from quartz lodes in the Mesozoic Nicoya ophiolite complex was reconcentrated through three generations of Quaternary sedimentary deposits. Resultant gold placers grade upward from 1 g/m3 (0.03 troy oz/m3) and are of moderate size.

Jan 1, 1980

By Robert Yerkes

THE following is a brief account of the methods of measuring intelligence especially prepared for use in the U. S. Army, of typical results, and of some of their immediately practical applications. It has been prepared for the assistance of army examiners and for the information of all who are interested in the relations of scientific placement to military efficiency. PURPOSE OF THE INTELLIGENCE TESTS Under the direction of the Division of Psychology, Medical Department, and in accordance with provisions of War Department General Order No. 74, mental tests are given recruits during the 2-wk. detention period. These tests provide an immediate and reasonably dependable classification of the men according to general intelligence. Their specific purposes are to aid: 1. In the discovery of men whose superior intelligence suggests their consideration for advancement; 2. In the prompt selection and assignment to development battalions of men who are so inferior mentally that they are suited only for selected assignments; 3. In forming organizations of uniform mental strength where such uniformity is desired; 4. In forming organizations of superior mental strength where such superiority is demanded by the nature of the work to be performed; 5. In selecting suitable men for various army duties or for special training in colleges or technical schools; 6. In the early formation of training groups within regiment or battery in order that each man may receive instruction and drill according to his ability to profit thereby;

Jan 2, 1919

By J. H. Jensen

Bromine is the intermediate member of the halogen family of elements between iodine, a solid: and chlorine, a gas. The name is derived from the Greek "bromos," meaning stench. Bromine is the only nonmetallic element that is liquid at room temperatures with a melting point of -7.2" C and a boiling point of 58.78" C. Reddish brown in color, it dissolves easily in water to yield a red solution. Bromine volatilizes at ordinary temperatures to a red vapor that is very irritating to the eyes, nose, and throat. Density of the liquid is 3.12 and gas weighs 7.59 gpl at standard conditions. As the element is highly active, it exists in nature only as bromide compounds. Bromine was discovered by Antoine Jerome Balard in seawater bitterns in 1826 and first prepared in quantity in 1860. Distribution Bromine is widely distributed in nature and compounds occur in solution in natural brines, in seawater, saline lakes, oil and gas well brines, and in evaporite chloride minerals. The concentration of bromine salts ranges from 60- 65 ppm in seawater to several thousand ppm in oil well brines and saline lakes. The distribution of bromine in marine evaporite minerals and in the solutions from which they crystallized was determined many years ago by H. E. Boeke (1 908). Theoretical aspects regarding the geochemistry of bromine have been published in numerous papers (Raup and Mite, 1969). Bromine occurs in solid solution in carnallite and sylvite associated in potash de- posits; in halite in salt beds; salt in oil shales; and in trona deposits. Its presence is useful as a guide in geochemical exploration. The analysis of small amounts of bromides in the presence of large amounts of chlorides is discussed by W. Schwerdtner (1963). Manganese, iron, and iodine may interfere with the determination. Other analytical methods are discussed at length in the literature (Stenger and Atchison, 1964). Sources and Reserves The sources and reserves of bromine, given in [Table 1], appear ample to meet present and foreseeable requirements in all producing countries. With the occurrence of bromine salts in sea-water and other brines, the potential for bromine production is worldwide. It has been estimated that 99% of all commercially recoverable bromine is in the ocean. However, actual subterranean brines having a higher bromine content than seawater will continue to be the preferred sources of bromine for the foreseeable future. Markets and Prices About 17% (1968) of bromine produced is used in its elemental form, with the balance consumed as bromides and bromates. The largest use for bromine is ethylene dibromide which, together with tetraethyl lead, are used as an antiknock additive in gasoline. Tetra-ethyl lead is the antiknock agent. Ethylene dibromide combines with the lead after combustion in the engine to form a volatile com- pound that escapes from the engine with the exhaust gases.

Jan 1, 1975

Addicks, L Ambler, J O Anderson, F B Armstrong, T Allen, L M, Jr Arnold, C E Adams, C E Adams, R E Anderson, A J Booth, E L Bernhardt, D I Boyd, W S Browning, W C Blake, D E Black, T B Bergman, Julius Bowen, H P Beckett, P G Blickensdefer, F C Bond, Josiah Butler, P P Bondlas. Y

Jan 1, 1923

By AIME AIME

Russell B. Paul, Chairman of the Special Committee on Divisional Relationships, presented the interim report of his Committee which was published in the September, 1945, issue of MINING AND METALLURGY and a copy of which is incorporated in the official minutes of this meeting. The following specific actions were taken by the Board of Directors in relation to the six recommendations in the Summary of the Report as published: (1) Mr. Haider, Chairman of the Petroleum Division, presented the formal request of his Executive Committee that the headquarters of the new Secretary of the Petroleum Division be established in Dallas, Texas. After lengthy discussion in which the point was made that the success of this program would depend upon effective co-operation between the Chairman of the Division, the Secretary of the Petroleum Division, and the Secretary of the Institute, the request was approved. The new secretary will be selected by the Division and will be employed by the Institute in the capacity of an Assistant Secretary. (2) The following item in the report was approved:

Jan 1, 1945

E. O?C. Acker Jinzoc Adachi Truman H. Aldrich Walter H. Aldridge Anson W. Allen John H. Allen William R. Appleby W. Lawrence Austin W. S. Ayres David Baker John Henry Banks Henry C. Banon Alonzo F. Bardwell Wm de L. Benedict Robert Bentley Andrew A Blair Walter M. Brodie Elwin F. Brown Fredrick Burbidge H.H. Burden Charles Butters

Jan 1, 1942

By W. L. Grose, J. E. Nealy

A device developed by the U.S. Bureau of Mines for the detection and quenching of coal mine explosions suffers from the inability to discriminate between the light emitted from hydrocarbon combustion and that emitted by electrical sparks and miner's cap lamps1. Since the quenchant device is activated by an internal explosive charge, the possibility of serious injury to nearby personnel demands a detector which can reject false signals. Described herein is a detector which can provide a rapid response signal upon the emission of radiation from hydrocarbon combustion and concurrently reject spurious signals from such sources as sparks and cap lamps. It was suggested that a detector might be developed to operate on the principle of monitoring the radiation intensity emitted from two separate spectral regions and ratioing the intensities2. A series of experiments was conducted for combustion of methane-air mixtures which demonstrate the ability of such a detector to discriminate between combustion and spurious signals. Experimental Apparatus A cylindrical (3.8 in. diam by 12 in.) stainless-steel shock tube test section was used as a combustion chamber. The test section was equipped with quartz windows (2 in. diam) on either side, a piezoelectric pressure transducer, and two steel electrodes. A 10-kv capacitor discharged across the electrodes provided a submicrosecond duration spark to ignite the gas mixture within. The desired partial pressures of methane and air were obtained by using a Wallace and Tiernan 0-800 mm Hg pressure gauge with which pressures could be determined to an accuracy of % mm Hg. All tests were conducted with a total pressure of 1 atm in the chamber. To

Jan 1, 1972

E. O?C. Acker Jinzoc Adachi Truman H. Aldrich Walter H. Aldridge Anson W. Allen John H. Allen William R. Appleby W. Lawrence Austin W. S. Ayres David Baker John Henry Banks Henry C. Banon Alonzo F. Bardwell Wm de L. Benedict Robert Bentley Andrew A Blair Walter M. Brodie Elwin F. Brown Fredrick Burbidge H.H. Burden Charles Butters

Jan 1, 1941