Planejamento tributário: Critérios e limites para a desconsideração dos atos e negócios jurídicos pela administração fiscal

Tax planning is a subject that has been increasing in relevance in Tax Law. This current dissertation s objective is to approach the criterion and limits for the disqualification of law acts and business through the Tax Administration. Law acts and business resulted from the conduct of contributors that seek to diminish the growing raise of the tax load, using some means to reduce their burden and increase the possibilities of success in an economical activity, without violating the law in the persecution of paying fewer burdens. On the other hand, the tax administration, through its organs, hoping the increase of burden collection to withstand some determined sectors of the State, with a clear purpose to stop the contributor organizing his activity and structuring it as efficiently as possible, came up with a preliminary draft which left Complementary Law 104, from 10.02.2001, enacted, that inserted the unique paragraph of the National Tax Code, article 116, authorizing the disregard, by the administrative fiscal authority, of Law acts and business practiced to dissimulate the occurrence of burden gain or the nature of obligated incorporating elements, observing the procedures to be established in common law . Our goal is to identify the criteria and limits to disregard law acts and business through the tax administration, pointing out some possible means of action by the tax administration that qualifies it to disregard the contributor s acts and business, just claiming that a saving in the tax costs was made by the contributor s act

Entre a fé, a obra social e a publicidade: uma análise crítica do discurso da responsabilidade social da Igreja Universal do Reino de Deus

Situated on Applied Linguistics (PENNYCOOK, 1998; MOITA LOPES, 2003, 2006, 2008, 2009), this thesis, which is inscribed in a qualitative-interpretative approach of a critical analysis perspective , lies on the speech of social responsibility and the way like that is employed in seeking for legitimacy and prestige within the neopentecostal brazilian religious field, more specifically of the Universal Church of the Kingdom of God. The general goal of this research is t reflect upon the speech on social responsibility and the rethoric of selfpromotion of the Universal Church through the role of social actors in the making of his her identities, materialized in the newspaper Folha Universal. In order to achieve that, we have conjugated, in this research, social and discursive analysis. On the linguistic-discursive approach, the research is based on the Critical Analysis of Discourse (ACD), specially in Fairclough (2001, 2003, 2006), a proposal that provides theoretical-methodological tools to investigate the language beyond the linguistic structures , that is, the discourse, social practices in which it occurs and more ample structures. Theoretical assumptions were also used of Sistemico-Functional Linguistics(LSF), matching with categories of the Transitivity System of Halliday (1994, 2004), of the forms of representation of social actors in the socioeconomic perspective by Van Leeuwen (1997, 2008) and of the Appraisal system by Martin and White (2005). As we develop the argumentation on thesobre social role of religion in this thesis, we make use of the authors such as Freston (1994), Oro (1997, 2003), Campos (1996, 1999), Mariano (1999), Meneses (2008), among several ones. We have also used a series of concepts and categories coming from the field of communication and marketing on the business social responsability and social marketing . In this area, we take as references the contributions of Bueno (2003), Fossá and Sartoretto (2003) and Zenone (2006). The corpus of the work is framed by news taken at the newspaper Folha Universal, in which are given the social responsibility actions of the church . The timeframe used was on the editions of 2010 thru 2012. Results found at he analysis of the News lead to semantic features of Assessment of Affection, Judgment and Appreciation, many times followed by Gradation, and the Attribution, one of the subsystems of the Attachment, are evidence of positive assessments for the Universal Church and its agents and make up rethorical elements which provide structure for the discourse of the Universal Church at the newspaper Folha Universal consisted of its image (style) of social responsibility . Results show that the most frequente social actors of the discourse are, on one hand, the Universal Church itself and its volunteers, famous (actors, actresses, presenters), politicians and authorities, on the other hand, the population which was helped by the Church social projects . The first group seems to be Always activated, however the second one, most of the time rather passive. These are also represented by assimilation in most of the occurrences, however the other ones by individualization and nomination entitled by honorification, except for the volunteers that are represented either as an individual, or as a group

Publicidade e moda: um estudo sobre a materialidade da mídia e a produção de sentido na revista ffw>>mag!

The proposal of this research is to analyze the convergence between fashion and communication shown on the materiality of the print media, and how the language from the supporter influences on the production of sense by the target market. Made real in the research corpus comprised of six ffw>>mag! magazines from the year 2011. The applied conceptual mechanism tries to investigate the production of sense from the physical attributes before interpreting the message s content, to do so, the Materiality of Communication is used, which offers an investigative apparatus of the media in its material shape, and those as influences in the communicative acts and processes. Methodologically, we adopt the Peircean Semiotics Theory, for its study focus on the analysis of the possible processes of production of sense. Through Semiotics we achieve the interpretative levels that allow us to clarify the questionings that come from the research s objectives, identifying and tracing the cognitive and intelligibility schemes bound to the media speeches of materiality. The analysis coordinated to the concepts and theories employed in this study point to a confirmation that the materiality of the reviewed media communicates to the readers in the same intensity as its content, provides a preview of the content and notifies the intentions of the publication. In the commercial way, characterizing the target audience it craves, and also in the conceptual way, demonstrating the ideas it wants to communicate. Where the convergence between communication and fashion unfolds as the materiality of the media by the choice of the materials and finishing options, and mainly by the selection and manipulation of technical images and colors from the cycles of fashion

Desenvolvimento e implantação de um sistema de gestão de pedidos de informação endereçados à Universidade Federal do Rio Grande do Norte a partir do serviço de informações ao cidadão (E-SIC)

Among the numerous policy changes that the world has experienced in recent years, occupies a prominent place in the quest for greater transparency of public agencies. Transparency has been an important tool in the accountability of the State to promote greater participation of the society by providing information that was previously restricted knowledge of public agencies. Brazil, following this trend, promulgated in May 2012 the Access to Information Act that seeks to disclose the actions of the State at all levels, in all public administration agencies. On the same day of the enactment of the law is provided society with a site that is empowering citizens to make their requests for information to government agencies. The Federal University of Rio Grande do Norte, which at that time had no a tool to assist them in managing this demand. This project has the objective to describe, build and implement a solution to solve this problem using Design Science Research as methodology. As result, the solution built in this research became a new module of the institution s ERP became it capable to control the entire process, and will be helpful to others partners which use our system ERP

Cargos comissionados da administração pública direta do Rio Grande do Norte: análise comparativa entre o perfil profissional dos cargos comissionados com vínculo funcional e sem vínculo funcional

The professional profile of public administrators in Brazil is changing very rapidly in recent years, seeking to meet the principle of efficiency by public agencies at all levels. The admission of the permanent government employee under the Public Administration is by competition, however, commissioned positions are free appointment of managers, which allows effective participation of external experts according to their respective standards and norms. In this context, this dissertation seeks to understand the main characteristics of the profile of the occupants of commissioned positions in Direct Public Administration of the State of Rio Grande do Norte, noting the differences between those with functional link with the have nots. For this study, by data collection and content analysis, a mapping of the administrative structure of the Government of the State of Rio Grande do Norte was done, i.e., the organization of the Executive Branch, which is regulated by the Complementary Law no. 163/1999 and its amendments, which consists of 53 (fifty three) entities, these 29 (twenty nine) are agencies of the direct administration and the remaining 24 (twenty four) comprises the indirect administration. With the collected data, analysis on the number of commissioned positions of each organ of the State of Rio Grande do Norte and information on education, age, length of service, gender and functional link with the direct administration was carried out. Data were available from SEARH in June/2013, when they totaled 58,733 (fifty-eight thousand seven hundred thirty-three) servers, these 2.15% (two point fifteen percent) occupy commissioned positions, corresponding to 1,262 commissioned positions under the Direct Administration, below the national average of 4% (four percent). Of total commissioned positions 64.7% (sixty-four point seven percent) have no functional link with the direct administration, while only 35.3% (thirty -five point three percent) have functional link. It was noticed that there are no clear and specific criteria for the appointments of commissioned positions in the State. They occur freely, as provided in the State Constitution. Another conclusion is the importance of Public Administration define and improve their capacity, competence and efficiency in the delivery of public services. For that it is necessary to invest in their workforce composed of permanent employees and commissioned positions to define the appropriate professional profile

O plantador de cidades e a criação do espaço moderno : a construção de uma Natal moderna na administração Sylvio Pedroza (1946-1950)

O propósito deste trabalho é analisar as transformações sofridas pelo espaço urbano da cidade do Natal durante a gestão do prefeito Sylvio Piza Pedroza (1946-1950). Neste intuito, nos esforçamos em analisar em que sentido os discursos e as respectivas representações da cidade moderna foram responsáveis pela construção de novos espaços na capital do Rio Grande do Norte, espaços que por sua vez, foram utilizados para justificar duplamente a gestão Piza Pedroza, e o próprio prefeito enquanto exemplos de um momento de modernidade e progresso da cidade. No intuito de responder nosso objetivo, analisamos no decorrer da dissertação três elementos fundamentais para a construção dessa Natal moderna da gestão Piza Pedroza. Dentre eles destacamos as representações construídas pelos jornais natalenses, recifenses e fluminense; a imagem forjada e a relação de legitimação (a partir do espaço da cidade de Natal) possibilitada pela relação entre Câmara Cascudo e Sylvio Pedroza. Por último, analisamos o Arquivo Sylvio Pedroza (ASP), da Fundação José Augusto, percebendo esse suporte como um espaço de inscrição do sujeito e da cidade moderna. Nessa última etapa nos detivemos na apreciação das correspondências e nas fotografias do ASP, percebendo como essas fontes são fundamentais na elaboração e seleção das paisagens modernas da Natal da segunda metade da década de 1940

Efeitos da administração aguda de quetamina sobre as oscilações eletrofisiológicas da região CA1 hipocampal

Coordenação de Aperfeiçoamento de Pessoal de Nível Superior

Administração repetida de baixas doses de reserpina: um possível modelo para o estudo de déficits cognitivos e motores associados à Doença de Parkinson

Parkinson's disease (PD) is one of the most common neurodegenerative brain disorders and is characterized primarily by a progressive degeneration of dopaminergic neurons nigroestriatais. The main symptoms of this disease are motor alterations (bradykinesia, rigidity, tremor at rest), which can be highly disabling in advanced stages of the condition. However, there are symptomatic manifestations other than motor impairment, such as changes in cognition, mood and sensory systems. Animal models that attempt to mimic clinical features of PD have been used to understand the behavioral and neural mechanisms underlying neurophysiological disturbance of this disease. However, most models promote an intense and immediate motor impairment, consistent with advanced stages of the disease, invalidating these studies for the evaluation of its progressive nature. The administration of reserpine (a monoamine depletor) in rodents has been considered an animal model for studying PD. Recently we found that reserpine (in doses lower than those usually employed to produce the motor symptoms) promotes a memory deficit in an aversive discrimination task, without changing the motor activity. It was suggested that the administration of this drug in low doses can be useful for the study of memory deficits found in PD. Corroborating this data, in another study, acute subcutaneous administration of reserpine, while preserving motor function, led to changes in emotional context-related (but not neutral) memory tasks. The goal of this research was to study the cognitive and motor deficits in rats repeatedly treated with low doses of reserpine, as a possible model that simulates the progressive nature of the PD. For this purpose, 5-month-old male Wistar rats were submitted to a repeated treatment with vehicle or different doses of reserpine on alternate days. Cognitive and motor parameters and possible changes in neuronal function were evaluated during treatment. The main findings were: repeated administration of 0.1 mg / kg of reserpine in rats is able to induce the gradual appearance of motor signs compatible with progressive features found in patients with PD; an increase in striatal levels of oxidative stress and changes in the concentrations of glutamate in the striatum were observed five days after the end of treatment; in animals repeatedly-treated with 0. 1 mg/kg, cognitive deficits were observed only after the onset of motor symptoms, but not prior to the onset of these symptoms; 0.2 mg / kg reserpine repeated treatment has jeopardized the cognitive assessment due to the presence of severe motor deficits. Thus, we suggest that the protocol of treatment with reserpine used in this work is a viable alternative for studies of the progressive appearance of parkinsonian signs in rats, especially concerning motor symptoms. As for the cognitive symptoms, we suggest that more studies are needed, possibly using other behavioral models, and / or changing the treatment regimen

Infância na publicidade: um estudo sobre o trabalho de crianças na publicidade na cidade de Natal-RN

In Brazilian scene the child labor is a serious and relevant theme regarding issues that involve infancy, arousing the interest and concerning of public and private institutions, and organized civil society. Thus, the child labor is forbidden by the law, considered that the child worker have a distinguished life experience, especially because it is demanded them the early mature of some skill, generating implications on their physical, emotional, cognitive, social and psychological development. Observing those issues, we proposed think the child labor, over and above those considered the worst forms of one and more found in literature, what lead us to think the child labor in the advertising. In that way, this research aimed to investigate the insertion and development conditions of children who work in advertisements, and the possible effects on their lives in the face of that insertion. Participated of this study: three advertising agencies, six video producers companies, one child model s agent and five children with their respective families. Those children were four boys and two girls, with ages between seven and eleven years old, which one that have accomplished four or more advertisements, in Natal city, Rio Grande do Norte. Based on social-historical perspective, we used the semi-structured interview as methodological instrument, which underlays the comprehension of the data obtained in field research processes. This study revealed that when children are inserted in the advertising activities they are submitted to irregular and adverse work situations, what occurs in others productive activities mentioned in the literature. The data still exposed that the family is the main responsible to the children insertion in the advertisement work; moreover, there is an ambiguousness of wishes in relation of that activity. On the other hand, we realized that the legal content concerning to the child labor forbidding, carries contradictory aspects in face of the ECA s 149 article, that one, under some conditions, allows that a child take part in the activities of advertising context. This highlights the necessity of a rigorous evaluation of the children insertion in the advertising, in order to ensure the whole children and adolescents protection. This study put in evidence the complexity that involves the child labor in this context, mainly, due to the exposition and manipulation of the childish image on the media. Besides, we understand that the discussion on this subject should be stimulated and, therefore, enlarged this on over and above those considered the worst forms of child labor

Gestão por Competências em Organizações Públicas: O Processo de Transformação Organizacional e seus Impactos Junto aos Servidores na Secretaria Estadual de Administração e Recursos Humanos (SEARH/RN)

The state has changed over time in order to meet a society with increasingly stringent demands. Techniques of private means begin to be employed in an attempt to overcome the dysfunctions entrenched bureaucracy, making the machine faster. By federal law by the People Management Skills was established as a reference for the administration of Human Resources of the public sector in an attempt to develop professionally servers, based mainly on the three pillars of the model: the knowledge, skills and attitudes. This thesis aims at understanding, in the view of employees, the perceived impacts on the organizational changes occurring in the Department of Administration and Human Resources of the State of Rio Grande do Norte in order to implement a People Management Skills-based. It is a simple case study, characterized by the research during a certain period of time, collecting data in a real environment of an organization, in this case SEARH/RN. The procedures used in collecting data were the literature review, documental research and field research. We used a qualitative approach with exploratory and descriptive approach. Every reform was implemented in the institution and reported from there analyzed the impacts observed by the servers. As a result we observed a considerable advance in institutional activities, mainly relating to physical structure / organizational and human resource policies, with minor advances on labor policies, in much the result of the guiding focus of the reform on SEARH/RN. The impacts in total were more positive than negative and direct paths to improvement in public organizations. Making a general analysis of the modernization program implemented in SEARH/RN, we can conclude that there was a distinct change in all dimensions studied, mostly pointing out positive aspects, and contrary to the opinion of some authors, who claim to be very difficult to implement reforms in public organizations, since they are highly institutionalized environments. What was found was a big organization, with gaps and weaknesses, but with a much larger number of hits and recognition from institutional actors

Aspectos constitucionais da anulação de decisão definitiva da administração pública federal no processo tributário

Cet article traite de la possibilité de proposer le Trésor à la justice pour annuler une décision administrative définitive sur les questions fiscales. Il s'agit d'un sujet qui s'oppose au principe de la vérité matérielle - qui doit prévaloir en cas d'impôt - avec une certitude morale représentée par la chose jugée administrative. Commence par le processus administratif d'impôt comme une garantie constitutionnelle du contribuable, insérée dans le panorama d une compétence adoptée dans la législation brésilienne en tant que pilier de l'Etat de droit démocratique. Met l'accent sur la position du Trésor avant l'autorité de la chose jugée administrative, ce qui démontre la fragilité de La décision finale sur les questions fiscales. Décrit les effets de la révision (ou de l'annulation) dês actes administratifs, en particulier la libération de l'impôt et de la décision administrative qui vise à le confirmer. Enfin, nous discuterons de la composition et la légitimité du contentieux administratif, en conclusion, avec le soutien de la prévalence d'un fait important dans le cãs d'impôt, est non seulement possible, mais le Trésor devrait examiner leurs propres actions si nécessaire

Sustentabilidade e responsabilidade socioambiental: crenças provendo a formação de graduandos em administração

This research aims to focus on the education problem, since its source of development is the Research Base: Teachers Training and Qualification of UFRN. Therefore, we seek guidance in the beliefs in sustainability to propose plausible alternatives to promote the education process of UFRN administration undergraduates in order to meet the demands of a market-oriented society, since the market trend is to evolve from environmental guided activities, and future administrators should be trained to meet those conditions. The need to develop an instrument capable of understanding the beliefs of undergraduates on the sustainability problem becomes the object of analysis. This research aims to develop a normative questionnaire to study administration students beliefs in sustainability. The complexity and sensitivity of this research required the integration of various methodological procedures. These proposals were made as follows: analysis and selection of literature, expert validation procedures and psychometric methods and statistics. As for the literature, types of sustainability were identified and categorized, such as: political, social, economic and environmental sustainability. However, it is understood that the educational type, although included in all of those, needed to be converted into another type to fit the theme, since education is believed to be the best way to raise awareness about sustainability. Thus, it was required the categorization of the types, which was defined using criteria such as: contexts, objectives, goals, pathways and hypotheses. The normative questionnaire was the guiding instrument to investigate the role of administration students, regarding the level of knowledge established and regulated by social educational context, especially by becoming a basic condition for carrying out research on beliefs. The study confirmed that the types of sustainability - political, social, economic, environmental and educational - for having institutionalized literatures as sources, in international and national levels, are representative in the identification of future administrators. Therefore, it is believed that the types of sustainability categorized to provide a characterization of sustainability include the structuring of knowledge for undergraduates. The economic and political types, however, were not as representative with respect to their typicality and polarity indices as the educational, environmental and social ones. Although the beliefs of the undergraduates show how much they share ideas on all types, they present more identification with the educational and environmental types. Finally, it is expected that this instrument be subject to application in similar contexts so that it can ascertain whether such statements are part of the knowledge structure of future administrators from other institutions. Therefore, it is expected this strategy to strengthen the validation of the normative questionnaire

A educação informal para o consumo infantil e juvenil na televisão e na mídia

The consumption has become a major pillar of modern capitalism and at the same time, one of the factors that relate to social inequality. Karl Marx developed the theory of historical materialism which maintains a history of society determined by class struggle and the! exploitation of man by man. Considered to be overtaken by those who believe that Marxism is synonymous with real socialism, the Marxist ideals seem more present than in the Western world which each individual takes the individualization (loss of sense of public and collective) and the alienation by the work. Weassumed we could work on these issues in student education, even in elementary school, through questioning of the consumer society, with the criticism of television and the media, the main promoter of the current sense of consumption, as an initial step that could lead to future autonomy of theindividual. The theory of ideology and ideas of Paulo Freire's liberating education theory permeated the experience that happened as a participant observation of groups in the discipline of sociology in the unit 2 of the Colégio Pedro II in Rio de Janeiro, the state capital, an institution under the direct administration Ministry of Education. Wehave found fertile ground in which the students were able to understand and question the meaning of advertising media