The rules and concepts which govern "international taxation" among the major trading nations derive from work in the 1920s by the League of Nations. The principles first enunciated there are widely ...seen as having generated a remarkably durable and stable regime, lasting nearly a century to the present day. In the first half of this second decade of the twenty-first century, the major economic powers of the world undertook an initiative widely seen as aimed at, or having the potential to, substantially revise this existing but aging regime. The initiative was called the Base Erosion and Profit Shifting project, or, by its acronym, BEPS. Undoubtedly the most significant single facet of the historic regime are the rules governing "transfer pricing," which allocate the tax base generated by the profits of transnational enterprises (TNEs) among the national jurisdictions within which those enterprises operate. And despite the stability of the overall system, the "transfer pricing" rules have always proved neither durable nor satisfactory. The rules operate under the so-called "arm's length" principle-the idea that allocation of profits among countries should be accomplished by treating the TNEs as if the enterprises in different jurisdictions were separate enterprises engaged in transactions at prices that would be charged between independent enterprises. This paper advocates a middle view, which sees the "value creation" paradigm not as a departure from international norms but as a useful, if not profound, elaboration of it. In our view, the fundamental principle of the international system is that the right to tax income is allocated in the first instance to the state to which that income bears the greatest degree of "economic allegiance." The primary purpose of this paper is to explain this middle view, and to document the basis for seeing what we call the "value creation" paradigm as continuous with, rather than at odds with, the system which originated a near century ago and which prevails today.
Summary
Von Willebrand disease (VWD), caused by deficiency of the von Willebrand factor (VWF), is the most common bleeding disorder in humans and dogs. The complete cDNA encoding VWF of a German ...Wirehaired Pointer with type 2 VWD was sequenced, and we found four variants that alter the amino acid sequence. These variants were: c.1657T>G corresponding to p.Trp553Gly; c.1777G>A (p.Glu593Lys); c.4937A>G (p.Asn1646Ser) and c.5544G>A (p.Met1848Ile). A haplotype of the c.1657G, c.1777A and c.4937G alleles co‐segregated with the VWF antigen level in a four‐generation pedigree with the disease. Healthy dogs of the breed were found that were homozygous for the c.1777A or the c.5544A allele, indicating that these variants do not cause VWD. Dogs that were homozygous for the c.4937G allele and had no signs of a bleeding disorder were observed in the Chinese Crested dog breed. Thus, only the c.1657G variant was found in the homozygous state exclusively in VWD affecteds, and this variant is the strongest candidate to be the cause of VWD type 2 in the German Wirehaired Pointer breed. A screen of German Shorthaired Pointers indicated that the variant also segregates with VWD in this breed.
We describe a patient with a testosterone-producing metastasis discovered during the follow-up of prostate cancer. The patient had a history of a Leydig cell tumor (LCT) in the right testicle for ...which he underwent radical orchiectomy at the age of 60 years. Within a year after orchiectomy, he was diagnosed with prostate cancer. He received a radical prostatectomy with pelvic lymph node dissection. Due to recurrent prostate cancer, he underwent salvage radiation to the prostatic fossa and pelvic lymph node stations with hormonal treatment for 3 years. After approximately 1.5 years of chemical castration, a significant increase in testosterone level occurred. Further, diagnostic evaluations and surgery revealed a testosterone-producing LCT metastasis in the retroperitoneum.
Based on a survey of participants in eight negotiated rule makings at the Environmental Protection Agency and in six comparable conventional EPA rule makings, we find that, when the rule is ...negotiated, there is greater satisfaction with the substance of the final rule (e.g., net benefits to the respondent's organization, general effectiveness/efficiency) and with the overall process. Participants in negotiated rules also learn more, but they face higher costs. Rules selected for negotiation appear more complex and involve detailed issues of compliance. There is no difference between the rule makings in the perceived net benefits of participation, in the perception of parties being left out or a party with disproportionate influence, in the overall responsiveness of EPA to public participation, or in the amount of litigation. The results are consistent with theoretical arguments that support the benefits of face-to-face negotiation among affected parties under certain circumstances, but they leave important questions about efficiency and equity unanswered
China has a highly centralized bureaucracy that is no longer strictly monitored by political loyalty but by governance performance (e.g., economic growth), rewarded with promotion and monetary ...incentives. In the early 2000s, environmental criteria were added to this system. As part of this effort, a high-powered performance management system was introduced in 2006. It held high-level provincial officials, who are part of the nomenklatura, personally responsible for meeting specific emissions targets. Using data from China Statistics Yearbooks and several official news archives, the empirical results indicate that the implementation of the new performance management system reduced emissions only for air pollutants, which are the most publicly visible among the targeted pollutants. Water pollution, which is less visible but also a mandated target, was unaffected. Emissions of soot, an untargeted pollutant, were also unaffected. The findings imply that, even in centrally managed systems like China, compliance with a high-stakes reward for measured performance is not universal.
Fingerlike structures reaching from lower into extra-tropical latitudes significantly contribute to the tropical-extratropical exchange of air masses. This is also an exchange of upper tropospheric ...and stratospheric air. Those so called streamers can, on a horizontal plane, be detected in N2O or O3 since they are characterised by high N2O or low O3 values compared to undisturbed mid-latitude values. A climatology of streamer events has been established, employing the chemical-transport model KASIMA, which is driven by ECMWF re-analyses (ERA) and operational analyses. For the first time, the seasonal and geographical distribution of streamer frequencies has been determined on the basis of 9 years of meteorological analyses. For the current investigation, a meridional gradient criterion has been newly formulated and applied to the N2O distributions calculated with KASIMA. A climatology has been derived by counting all streamer events between 21 and 25 km for the years 1990 to 1998. The results have been compared with a streamer climatology which has been established in the same way employing data of a multi-year simulation with the coupled chemistry-climate model ECHAM4.L39(DLR)/CHEM (E39/C). Both climatologies are qualitatively in agreement, in particular in the northern hemisphere, where much higher streamer frequencies are found in winter than in summer. In the southern hemisphere, the KASIMA analyses indicate strongest streamer activity in September. E39/C streamer frequencies clearly displays an offset from June to October, pointing to model deficiencies with respect to tropospheric dynamics. KASIMA and E39/C results agree well from November to May. Some of the findings give strong indications that the streamer events found in the altitude region between 21 and 25 km are mainly forced from the troposphere and are not directly related to the dynamics of the stratosphere, in particular not to the dynamics of the polar vortex. Sensitivity simulations with E39/C, which represent recent and possible future atmospheric conditions, have been employed to answer the question how climate change would alter streamer frequencies. This shows that the seasonal cycle does not change but that significant changes occur in months of minimum and maximum streamer frequencies. This could have an impact on the mid-latitude distribution of chemical tracers and compounds.
The public personnel system, particularly the compensation system, has long faced many criticisms such as inflexibility and un-competitiveness when compared to other sectors. This is especially true ...for compensation systems for K-12 teachers, who also care about public service values, even if they work in the non-public sectors. We examine wage competition for teachers between the three K-12 sectors within metropolitan market areas, even with controls for many other variables. While the public sector is clearly the dominant (but not monopsonist) buyer, it also responds to wage competitions from the other two sectors.
Aggregate indexes of the quality of governance, covering large samples of countries, have become popular in comparative political analysis. Few studies examine the validity or reliability of these ...indexes. To partially fill this gap, this study uses factor, confirmatory factor and path analysis to test both measurement and causal models of the six Worldwide Governance indicators. They purportedly measure distinct concepts of control of corruption, rule of law, government effectiveness, rule quality, political stability, and voice and accountability. Rather than distinguishing among aspects of the quality of governance, we find that they appear to be measuring the same broad concept.
Celotno besedilo
Dostopno za:
BFBNIB, DOBA, IZUM, KILJ, NUK, PILJ, PNG, SAZU, UILJ, UKNU, UL, UM, UPUK
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