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This paper considers how three jurisdictions, Canada, the United States and the United Kingdom, have sought to reconcile freedom of religion with equality rights, particularly in the commercial context, and particularly in relation to sexual orientation. The recent decisions of the United Kingdom Supreme Court and United States Supreme Court form the backdrop for that discussion. It is argued that the former made piecemeal, and misleading, use of American case law, and a fuller consideration of that jurisdiction's position was warranted, and would have led to a different view of the recent American decision. It argues that the United Kingdom Supreme Court was in error in viewing a message on a cake ordered from a baker as an example of the baker's expression, leading it to an incorrect conclusion at odds with statutory mandates in the commercial sphere around refusals of service. Both high court decisions risk undermining progress on the equality front. [ABSTRACT FROM AUTHOR]

Substantial cross-national differences in poverty alleviation are well documented. But the extent to which different parts of the social transfer system account for this variation is still relatively unexamined. This paper analyses the redistributive effects of specific social policy institutions in a comparative perspective. The main question is to what extent non-means-tested entitlements and means-tested benefits reduce relative economic poverty in different institutional settings. It is shown that the structure of non-means-tested benefits is more important than that of means-tested benefits in explaining differences in poverty alleviation across countries. The paper also presents a new method for estimating the anti-poverty effects of separate parts of the social transfer system. This method decomposes the anti-poverty effects of a set of social transfers into independent and combined effects, which produces more valid results than prevalent methods used to assess the impact of a particular transfer on poverty. The countries included in this study are Canada, Germany, Sweden, the United Kingdom and the United States. The empirical analyses are based on data from the Social Citizenship Indicators Programme (SCIP) and Luxembourg Income Study (LIS) describing the situation in the mid-1990s. [ABSTRACT FROM AUTHOR]