Clarification of the Meaning of "Beneficial Owner" in the OECD Model Tax Convention: Comment on the April 2011 Discussion Draft

In April 2011, the OECD released an important discussion draft that is intended to clarify the meaning of the term "beneficial ownership" under articles 10, 11 and 12 of the OECD Model (2010). This article discusses these proposals and demonstrates that some refinement is necessary.

Prefabrication of composite grafts for long-segment tracheal reconstruction.

OBJECTIVE: To investigate the prefabrication of vascularized mucosa-lined composite grafts intended to replace circumferential tracheal defects. DESIGN: Plane grafts composed of ear cartilage and full-thickness oral mucosa were revascularized by the laterothoracic fascia. The use of meshed vs nonmeshed mucosa to improve the epithelial coverage was examined. We also investigated the creation of a vascular bed over the cartilage and the subsequent application of meshed mucosa. Macroscopic aspects, viability, and degree of mucosal lining were analyzed. SUBJECTS: Twenty male New Zealand white rabbits. INTERVENTIONS: Ten animals underwent placement of auricular cartilage under the laterothoracic fascia. Intact (group 1) or meshed mucosa (group 2) was applied over the fascia and protected by a silicone sheet. After 3 weeks, prefabricated grafts were removed for comparison. In 10 other animals, a sheet of perforated cartilage was placed under the laterothoracic fascia. Two weeks later, 5 grafts (group 3) were harvested. The remaining 5 grafts were reopened for mucosal application over the cartilage and revascularized for 3 additional weeks (group 4). RESULTS: Vascularized plane grafts were obtained in all groups. Mucosal lining increased significantly with meshed mucosa (14%-68%; mean, 40%) compared with nonmeshed mucosa (3%-15%; mean, 10%) (P = .008). Induction of a vascular bed over perforated cartilage was achieved, but survival of secondary implanted mucosa was variable. CONCLUSIONS: A reliable technique to prefabricate composite grafts with cartilaginous support and mucosal lining is presented. The use of meshed mucosa significantly improves epithelial coverage.

Draft genome of the globally widespread and invasive Argentine ant (Linepithema humile).

Ants are some of the most abundant and familiar animals on Earth, and they play vital roles in most terrestrial ecosystems. Although all ants are eusocial, and display a variety of complex and fascinating behaviors, few genomic resources exist for them. Here, we report the draft genome sequence of a particularly widespread and well-studied species, the invasive Argentine ant (Linepithema humile), which was accomplished using a combination of 454 (Roche) and Illumina sequencing and community-based funding rather than federal grant support. Manual annotation of >1,000 genes from a variety of different gene families and functional classes reveals unique features of the Argentine ant's biology, as well as similarities to Apis mellifera and Nasonia vitripennis. Distinctive features of the Argentine ant genome include remarkable expansions of gustatory (116 genes) and odorant receptors (367 genes), an abundance of cytochrome P450 genes (>110), lineage-specific expansions of yellow/major royal jelly proteins and desaturases, and complete CpG DNA methylation and RNAi toolkits. The Argentine ant genome contains fewer immune genes than Drosophila and Tribolium, which may reflect the prominent role played by behavioral and chemical suppression of pathogens. Analysis of the ratio of observed to expected CpG nucleotides for genes in the reproductive development and apoptosis pathways suggests higher levels of methylation than in the genome overall. The resources provided by this genome sequence will offer an abundance of tools for researchers seeking to illuminate the fascinating biology of this emerging model organism.

Properties of ideal composite knots.

The shortest tube of constant diameter that can form a given knot represents the 'ideal' form of the knot. Ideal knots provide an irreducible representation of the knot, and they have some intriguing mathematical and physical features, including a direct correspondence with the time-averaged shapes of knotted DNA molecules in solution. Here we describe the properties of ideal forms of composite knots-knots obtained by the sequential tying of two or more independent knots (called factor knots) on the same string. We find that the writhe (related to the handedness of crossing points) of composite knots is the sum of that of the ideal forms of the factor knots. By comparing ideal composite knots with simulated configurations of knotted, thermally fluctuating DNA, we conclude that the additivity of writhe applies also to randomly distorted configurations of composite knots and their corresponding factor knots. We show that composite knots with several factor knots may possess distinct structural isomers that can be interconverted only by loosening the knot.

Draft genome of the red harvester ant Pogonomyrmex barbatus.

We report the draft genome sequence of the red harvester ant, Pogonomyrmex barbatus. The genome was sequenced using 454 pyrosequencing, and the current assembly and annotation were completed in less than 1 y. Analyses of conserved gene groups (more than 1,200 manually annotated genes to date) suggest a high-quality assembly and annotation comparable to recently sequenced insect genomes using Sanger sequencing. The red harvester ant is a model for studying reproductive division of labor, phenotypic plasticity, and sociogenomics. Although the genome of P. barbatus is similar to other sequenced hymenopterans (Apis mellifera and Nasonia vitripennis) in GC content and compositional organization, and possesses a complete CpG methylation toolkit, its predicted genomic CpG content differs markedly from the other hymenopterans. Gene networks involved in generating key differences between the queen and worker castes (e.g., wings and ovaries) show signatures of increased methylation and suggest that ants and bees may have independently co-opted the same gene regulatory mechanisms for reproductive division of labor. Gene family expansions (e.g., 344 functional odorant receptors) and pseudogene accumulation in chemoreception and P450 genes compared with A. mellifera and N. vitripennis are consistent with major life-history changes during the adaptive radiation of Pogonomyrmex spp., perhaps in parallel with the development of the North American deserts.

Upper Triassic to Cretaceous radiolaria from Nicaragua and northern Costa Rica - The Mesquito composite oceanic terrane

We propose a new terrane subdivision of Nicaragua and Northern Costa Rica, based on Upper Triassic to Upper Cretaceous radiolarian biochronology of ribbon radiolarites, the newly studied Siuna Serpentinite Mélange, and published 40Ar/39Ar dating and geochemistry of mafic and ultramafic igneous rock units of the area. The new Mesquito Composite Oceanic Terrane (MCOT) comprises the southern half of the Chortis Block, that was assumed to be a continental fragment of N-America. The MCOT is defined by 4 corner localities characterized by ultramafic and mafic oceanic rocks and radiolarites of Late Triassic, Jurassic and Early Cretaceous age: 1. The Siuna Serpentinite Mélange (NE-Nicaragua), 2. The El Castillo Mélange (Nicaragua/Costa Rica border), 3.The Santa Elena Ultramafics (N-Costa Rica) and, 4. DSDP Legs 67/84. 1. The Siuna Serpentinite Mélange contains, high pressure metamorphic mafics and Middle Jurassic (Bajocian-Bathonian) radiolarites in original, sedimentary contact with arc-metandesites. The Siuna Mélange also contains Upper Jurassic black detrital chert formed in a marginal (fore-arc?) basin shortly before subduction. A phengite 40Ar/39Ar -cooling age dates the exhumation of the high pressure rocks as 139 Ma (earliest Cretaceous). 2. The El Castillo Mélange comprises a radiolarite block tectonically embedded in serpentinite that yielded a diverse Rhaetian (latest Triassic) radiolarian assemblage, the oldest fossils recovered so far from S-Central America. 3. The Santa Elena Ultramafics of N-Costa Rica together with the serpentinite outcrops near El Castillo (2) in Southern Nicaragua, are the southernmost outcrops of the MCOT. The Santa Elena Unit (3) itself is still undated, but it is thrust onto the middle Cretaceous Santa Rosa Accretionary Complex (SRAC), that contains Lower to Upper Jurassic, highly deformed radiolarite blocks, probably reworked from the MCOT, which was the upper plate with respect to the SRAC. 4. Serpentinites, metagabbros and basalts have long been known from DSDP Leg 67/84 (3), drilled off Guatemala in the Nicaragua-Guatemala forearc basement. They have been restudied and reveal 40Ar/39Ar dated Upper Triassic to middle Cretaceous enriched Ocean Island Basalts and Jurassic to Lower Cretaceous depleted Island arc rocks of probable Pacific origin. The area between localities 1-4 is largely covered by Tertiary to Recent arcs, but we suspect that its basement is made of oceanic/accreted terranes. Earthquake seismic studies indicate an ill-defined, shallow Moho in this area. The MCOT covers most of Nicaragua and could extend to Guatemala to the W and form the Lower (southern) Nicaragua Rise to the NE. Some basement complexes of Jamaica, Hispaniola and Puerto Rico may also belong to the MCOT. The Nicoya Complex s. str. has been regarded as an example of Caribbean crust and the Caribbean Large Igneous Province (CLIP). However, 40Ar/39Ar - dates on basalts and intrusives indicate ages as old as Early Cretaceous. Highly deformed Jurassic and Lower Cretaceous radiolarites occur as blocks within younger intrusives and basalts. Our interpretation is that radiolarites became first accreted to the MCOT, then became reworked into the Nicoya Plateau in Late Cretaceous times. This implies that the Nicoya Plateau formed along the Pacific edge of the MCOT, independent form the CLIP and most probably unrelated with he Galapagos hotspot. No Jurassic radiolarite, no older sediment age than Coniacian-Santonian, and no older 40Ar/39Ar age than 95 Ma is known from S-Central America between SE of Nicoya and Colombia. For us this area represents the trailing edge of the CLIP s. str.

Treatment of extended skin defects with autologous composite cultured skin grafts in a patient with epidermolysis bullosa

Rationale: The purpose of this article is to demonstrate the use of homologous culture cells in treating an advanced coccon formation of the hand and three extended squamous cell carcinomas of the lower and upper limb in a patient with recessive dystrophic epidermolysis bullosa. The preparation and application of these cells in the operation room are being described. Methods: A number of surgical approaches have been described to correct these deformities in order to improve function.We propose a new therapeutic approach of treating loss of motion and independent digital function as well as coverage of large skin defects in a patient with recessive dystrophic epidermolysis bullosa by using autologous culture cells. Surgical treatment of these patients is really difficult because of the existing skin fragility. Furthermore, surgical wounds do not easily heal because of recurrent blisters and erosions as well as due to the patients' poor nutricial status. Results: We report our experience of mutiple extended cutaneous squamous cell carcinomas arising in our patient which were successfully managed using autologous composite cultured skin grafts. The cocoon hand deformity was also treated with the limb becoming functional. Conclusion: The use of autologous keratinocytes and fibroblasts in epidermolysis bullosa is hereby outlined for the fist time.

A two-phase composite in simple shear: Effective mechanical anisotropy development and localization potential

We present a combined shape and mechanical anisotropy evolution model for a two-phase inclusion-bearing rock subject to large deformation. A single elliptical inclusion embedded in a homogeneous but anisotropic matrix is used to represent a simplified shape evolution enforced on all inclusions. The mechanical anisotropy develops due to the alignment of elongated inclusions. The effective anisotropy is quantified using the differential effective medium (DEM) approach. The model can be run for any deformation path and an arbitrary viscosity ratio between the inclusion and host phase. We focus on the case of simple shear and weak inclusions. The shape evolution of the representative inclusion is largely insensitive to the anisotropy development and to parameter variations in the studied range. An initial hardening stage is observed up to a shear strain of gamma = 1 irrespective of the inclusion fraction. The hardening is followed by a softening stage related to the developing anisotropy and its progressive rotation toward the shear direction. The traction needed to maintain a constant shear rate exhibits a fivefold drop at gamma = 5 in the limiting case of an inviscid inclusion. Numerical simulations show that our analytical model provides a good approximation to the actual evolution of a two-phase inclusion-host composite. However, the inclusions develop complex sigmoidal shapes resulting in the formation of an S-C fabric. We attribute the observed drop in the effective normal viscosity to this structural development. We study the localization potential in a rock column bearing varying fraction of inclusions. In the inviscid inclusion case, a strain jump from gamma = 3 to gamma = 100 is observed for a change of the inclusion fraction from 20% to 33%.

A composite stratigraphy for the Neoproterozoic Huqf Supergroup of Oman: integrating new litho-, chemo- and chronostratigraphic data of the Mirbat area, southern Oman

The Huqf Supergroup in Oman contains an exceptionally well-preserved and complete sedimentary record of the Middle to Late Neoproterozoic Era. Outcrops of the Huqf Supergroup in northern and central Oman are now well documented, but their correlation with a key succession in the Mirbat area of southern Oman, containing a sedimentary record of two Neoproterozoic glaciations, is poorly understood. Integration of lithostratigraphic, chemostratigraphic and new U-Pb detrital zircon data suggests that the Mirbat Group is best placed within the Cryogenian (c. 850-635 Ma) part of the Huqf Supergroup. The c. I km thick marine deposits of the Arkahawl and Marsham Formations of the Mirbat Group are thought to represent a stratigraphic interval between older Cryogenian and younger Cryogenian glaciations that is not preserved elsewhere in Oman. The bulk of detrital zircons in the Huqf Supergroup originate from Neoproterozoic parent rocks. However, older Mesoproterozoic, Palaeoproterozoic and even Archaean zircons can be recognized in the detrital population from the upper Mahara Group (Fiq Formation) and Nafun Group, suggesting the tapping of exotic sources, probably from the Arabian-Nubian Shield.

Multi-source composite kernels for urban image classification

This letter presents advanced classification methods for very high resolution images. Efficient multisource information, both spectral and spatial, is exploited through the use of composite kernels in support vector machines. Weighted summations of kernels accounting for separate sources of spectral and spatial information are analyzed and compared to classical approaches such as pure spectral classification or stacked approaches using all the features in a single vector. Model selection problems are addressed, as well as the importance of the different kernels in the weighted summation.

Emission of carbon nanofiber (CNF) from CNF-containing composite adsorbents

In spite of numerous applications of carbon nanofibers (CNFs) in a variety of fields, the potential release of airborne CNF during their special application, which could lead to workers or end-users exposure, has not been well investigated. In this study, the potential release of CNF from an organic vapour respirator cartridge was evaluated by carbon analysis and microscopy analysis. The cartridge consisted of an AC (Activated Carbon)/CNF composite adsorbent and different types of particulate filters. The composite adsorbent CNF were prepared by chemical vapour deposition (CVD). Air was passed through the prepared cartridge for 12 hours at 12 l/min and particles were collected on sampling filters suitable for measuring organic and elemental carbon (OC/EC) by carbon analysis based on the NIOSH 5040 method. Breakthrough of CNFs was also checked by scanning and transmission electron microscopy (SEM/TEM). This study found only minimal amounts of released elemental carbon while passing the air through the cartridge. Meanwhile TEM photos showed a few CNF structures for AC/CNF composite adsorbents which were not in the critical range in terms of length, aspect ratio, or number. [Authors]

Integrating life cycle costs and environmental impacts of composite rail car-bodies for a Korean train

Background, aim, and scope A coupled Life Cycle Costing and life cycle assessment has been performed for car-bodies of the Korean Tilting Train eXpress (TTX) project using European and Korean databases, with the objective of assessing environmental and cost performance to aid materials and process selection. More specifically, the potential of polymer composite car-body structures for the Korean Tilting Train eXpress (TTX) has been investigated. Materials and methods This assessment includes the cost of both carriage manufacturing and use phases, coupled with the life cycle environmental impacts of all stages from raw material production, through carriage manufacture and use, to end-of-life scenarios. Metallic carriages were compared with two composite options: hybrid steel-composite and full-composite carriages. The total planned production for this regional Korean train was 440 cars, with an annual production volume of 80 cars. Results and discussion The coupled analyses were used to generate plots of cost versus energy consumption and environmental impacts. The results show that the raw material and manufacturing phase costs are approximately half of the total life cycle costs, whilst their environmental impact is relatively insignificant (3-8%). The use phase of the car-body has the largest environmental impact for all scenarios, with near negligible contributions from the other phases. Since steel rail carriages weigh more (27-51%), the use phase cost is correspondingly higher, resulting in both the greatest environmental impact and the highest life cycle cost. Compared to the steel scenario, the hybrid composite variant has a lower life cycle cost (16%) and a lower environmental impact (26%). Though the full composite rail carriage may have the highest manufacturing cost, it results in the lowest total life cycle costs and lowest environmental impacts. Conclusions and recommendations This coupled cost and life cycle assessment showed that the full composite variant was the optimum solution. This case study showed that coupling of technical cost models with life cycle assessment offers an efficient route to accurately evaluate economic and environmental performance in a consistent way.

Independent sources of condition dependency and multiple pathways determine a composite trait: lessons from carotenoid-based plumage colouration.

Many colour ornaments are composite traits consisting of at least four components, which themselves may be more complex, determined by independent evolutionary pathways, and potentially being under different environmental control. To date, little evidence exists that several different components of colour elaboration are condition dependent and no direct evidence exists that different ornamental components are affected by different sources of variation. For example, in carotenoid-based plumage colouration, one of the best-known condition-dependent ornaments, colour elaboration stems from both condition-dependent pigment concentration and structural components. Some environmental flexibility of these components has been suggested, but specifically which and how they are affected remains unknown. Here, we tested whether multiple colour components may be condition dependent, by using a comprehensive 3 × 2 experimental design, in which we carotenoid supplemented and immune challenged great tit nestlings (Parus major) and quantified effects on different components of colouration. Plumage colouration was affected by an interaction between carotenoid availability and immune challenge. Path analyses showed that carotenoid supplementation increased plumage saturation via feather carotenoid concentration and via mechanisms unrelated to carotenoid deposition, while immune challenge affected feather length, but not carotenoid concentration. Thus, independent condition-dependent pathways, affected by different sources of variation, determine colour elaboration. This provides opportunities for the evolution of multiple signals within components of ornamental traits. This finding indicates that the selective forces shaping the evolution of different components of a composite trait and the trait's signal content may be more complex than believed so far, and that holistic approaches are required for drawing comprehensive evolutionary conclusions.