Financial strategies for minimizing corporate income taxes under Brazil's new global tax system

In 1996, Brazil adopted a worldwide income tax system for corporations. This system represents a fundamental change in how the Brazílian government treats multinational transactions and the tax minimizing strategies relevant to businesses. In this article, we describe the conceptual basis for worldwide tax systems and the problem of double taxation that they create. Responses to double taxation by both the governments and the priva te sector are considered. Namely, the imperfect mechanisms developed by Brazil and other countries for mitigating double taxation are analyzed. We ultimately focus on the strategies that companies utilize in order not only to avoid double texetion, but also to take advantage of tax havens.

Book-tax differences e gerenciamento de resultados no mercado de ações do Brasil

Este estudo verifica a relação entre book-tax differences (BTD) e gerenciamento de resultado em companhias listadas na BM&FBovespa no período de 2005 a 2009. Metodologicamente, foram empregadas duas abordagens: (i) distribuição de frequências e (ii) accruals discricionários - Modelo Jones Modificado. Os achados indicam uma relação diretamente proporcional entre a BTD e os accruals discricionários. Foram identificadas evidências de que as entidades preponderantemente gerenciam seus resultados na mesma direção do sinal observado da BTD, além de buscarem apresentar o montante de BTD em nível e em variação em torno do ponto zero e desta forma evitar sinalizar baixa qualidade do lucro. Adicionalmente, foram encontradas evidências de que o tamanho da firma e a adoção do regime tributário de transição estão relacionados de forma inversamente proporcional ao nível dos accruals discricionários.

Property and age organisation among an East African pastoralist group

Estudos sobre sistemas etários na África Oriental têm focado principalmente as regras que regulam recrutamento, com ênfase ao modo em que se mantém a autoridade e os cargos políticos, assim como à natureza não-militar e não-política dos sistemas etários. Apesar de contribuírem enormemente para a nossa compreensão das organizações etárias na região, esses estudos não lidam explicitamente com a questão da propriedade e com o modo em que ela constitui um dos principais focos para atividades de organizações etárias. De fato, quando se menciona a propriedade, ela é vista em função das famílias e, portanto, do parentesco. Apresentando e discutindo uma variedade de casos envolvendo o modo em que a propriedade é tratada por lideranças de um conjunto etário/geracional e residentes Hor e não-Hor do território Hor, este estudo conclui que a posse, o uso e controle de recursos não constitui um assunto que pertence exclusivamente à esfera de grupos de parentesco; trata-se também de uma questão central para organizações etárias. Apesar de haver, aparentemente, alguma ambigüidade decorrente da ênfase equilibrada que os Hor dedicam ao parentesco e às categorias etárias e suas complementaridades em assuntos relacionados à economia, à religião e ao direito, dados referentes aos Hor revelam uma tendência a tratar questões referentes ao uso de recursos cruciais em termos de organização etária. Trata-se de um estudo sobre os Hor (Arbore), um povo pastoril do Sudoeste da Etiópia.

Evaluation of temporal, seasonal and geographic stability of the molluscicidal property of Euphorbia splendens latex

Laboratory tests with aqueous solutions of Euphorbia splendens var. hislopii latex have demonstrated seasonal stability of the molluscicidal principle, with LD90 values of 1.14 ppm (spring), 1.02 ppm (fall), 1.09 ppm (winter), and 1.07 ppm (summer) that have been determined against Biomphalaria tenagophila in the field. Assays on latex collected in Belo Horizonte and Recife yielded LD90 values similar to those obtained with the reference substance collected in Rio de Janeiro (Ilha do Governador), demonstrating geographic stability of the molluscicidal effect. The molluscicidal action of aqueous dilutions of the latex in natura, centrifuged (precipitate) and lyophilized, was stable for up to 124 days at room temperature (in natura) and for up to 736 days in a common refrigerator at 10 to 12ºC (lyophilized product). A 5.0 ppm solution is 100% lethal for snails up to 13 days after preparation, the effect being gradually lost to almost total inactivity by the 30th day. This observation indicated that the active principle is instable. These properties together with the wide distribution of the plant, its resistance and adaptation to the tropical climate, its easy cultivation and the easy obtention of latex and preparation of the molluscicidal solution, make this a promising material for large-scale use in the control of schistosomiasis

Evaluation of the molluscicidal property of Euphorbia splendens var. Hispolii (N.E.B.) (Euphorbiaceae): 2. Investigation in lotic habitat

The latex of Euphorbia splendens var. hispolii in 12 ppm concentration (12 mg/l) caused 100% mortality for a Biomphalaria tenagophila population in a lotic habitat after 9 hr of dripfeed application. For sentinel snails, in cages placed at the water surface and buried under 0.10 m, the mortality rates varied with the distance from the application point and were: 100% (0 m); 92.6% (50 m) and 94.7% (100). No lethal effects were observed for the other living species in this habitat (Pomacea haustrum and Poecilia reticulata).

Lack of tax diversity for tropical spastic paraparesis/human T-cell lymphotropic virus type 1 (HTLV-I) associated myelopathy development in HTLV-I-infected subjects in São Paulo, Brazil

The product of human T-cell lymphotropic virus type 1 (HTLV-1) tax gene has a transactivating effect of the viral and cellular gene expression. Genetic variations in this gene have been correlated with differences in clinical outcomes. Based upon its diversity, two closely related substrains, namely tax A and tax B, have been described. The tax A substrain has been found at a higher frequency among human T-cell leukemia virus type 1 (TSP/HAM) patients than among healthy HTLV-I-infected asymptomatic subjects in Japan. In this study, we determined the distribution of tax substrains in HTLV-I-infected subjects in the city of São Paulo, Brazil. Using the ACCII restriction enzyme site, we detected only tax A substrain from 48 TSP/HAM patients and 28 healthy HTLV-I carriers. The sequenced tax genes from nine TSP/HAM patients and five asymptomatic HTLV-I carriers showed a similar pattern of mutation, which characterizes tax A. Our results indicate that HTLV-I tax subtypes have no significant influences on TSP/HAM disease progression. Furthermore, monophyletic introduction of HTLV-I to Brazil probably occurred during the African slave trade many years ago.

Immunostimulatory property of a synthetic peptide belonging to the soluble ATP diphosphohydro-lase isoform (SmATPDase 2) and immunolocalisation of this protein in the Schistosoma mansoni egg

A peptide (SmB2LJ; r175-194) that belongs to a conserved domain from Schistosoma mansoni SmATPDase 2 and is shared with potato apyrase, as predicted by in silico analysis as antigenic, was synthesised and its immunostimulatory property was analysed. When inoculated in BALB/c mice, this peptide induced high levels of SmB2LJ-specific IgG1 and IgG2a subtypes, as detected by enzyme linked immunosorbent assay. In addition, dot blots were found to be positive for immune sera against potato apyrase and SmB2LJ. These results suggest that the conserved domain r175-194 from the S. mansoni SmATPDase 2 is antigenic. Western blots were performed and the anti-SmB2LJ antibody recognised in adult worm (soluble worm antigen preparation) or soluble egg antigen antigenic preparations two bands of approximately 63 and 55 kDa, molecular masses similar to those predicted for adult worm SmATPDase 2. This finding strongly suggests the expression of this same isoform in S. mansoni eggs. To assess localisation of SmATPDase 2, confocal fluorescence microscopy was performed using cryostat sections of infected mouse liver and polyclonal antiserum against SmB2LJ. Positive reactions were identified on the external surface from the miracidium in von Lichtenberg's envelope and, in the outer side of the egg-shell, showing that this soluble isoform is secreted from the S. mansoni eggs.

Human milk for neonatal pain relief during ophthalmoscopy

Ophthalmoscopy performed for the early diagnosis of retinopathy of prematurity (ROP) is painful for preterm infants, thus necessitating interventions for minimizing pain. The present study aimed to establish the effectiveness of human milk, compared with sucrose, for pain relief in premature infants subjected to ophthalmoscopy for the early diagnosis of ROP. This investigation was a pilot, quasi-experimental study conducted with 14 premature infants admitted to the neonatal intensive care unit (NICU) of a university hospital. Comparison between the groups did not yield a statistically significant difference relative to the crying time, salivary cortisol, or heart rate (HR). Human milk appears to be as effective as sucrose in relieving acute pain associated with ophthalmoscopy. The study’s limitations included its small sample size and lack of randomization. Experimental investigations with greater sample power should be performed to reinforce the evidence found in the present study.

Analysis of private natural heritage reserves as a conservation strategy for the biodiversity of the cocoa region of the southern State of Bahia, Brazil

Brazil was the first country in Latin America to establish and regulate this type of reserve, and there are currently more than 700 Private Nature Heritage Reserves (RPPN in Portuguese) officially recognized by either federal or state environmental agencies. Together, these RPPN protect more than a half million hectares of land in the country. The coastal forests in the southern part of Bahia State extend 100 to 200 km inland, gradually changing in physiognomy as they occupy the dryer inland areas. The coastal forest has been subjected to intense deforestation, and currently occupies less than 10% of its original area. For this work the creation processes of the RPPN were consulted to obtain the data creation time, size of property, the condition of the remaining forest, succession chain and the last paid tax. After that, interviews with the owners were made to confirm this data. Sixteen RPPN have been established in this region until 2005. Their sizes vary from 4.7 to 800 ha. Ten of these RPPN are located within state or federal conservation areas or their buffer zones. In spite of the numerous national and international conservation strategies and environmental policies focused on the region, the present situation of the cocoa zone is threatening the conservation of the region's natural resources. The establishment of private reserves in the cocoa region could conceivably improve these conservation efforts. This type of reserve can be established under a uniform system supported by federal legislation, and could count on private organizations.

MODELING AND SIMULATION OF RELIEF INFLUENCE ON EUCALYPTUS FORESTS: INTERACTION BETWEEN SOLAR IRRADIANCE AND PRODUCTIVITY

ABSTRACT This study aimed to verify the differences in radiation intensity as a function of distinct relief exposure surfaces and to quantify these effects on the leaf area index (LAI) and other variables expressing eucalyptus forest productivity for simulations in a process-based growth model. The study was carried out at two contrasting edaphoclimatic locations in the Rio Doce basin in Minas Gerais, Brazil. Two stands with 32-year-old plantations were used, allocating fixed plots in locations with northern and southern exposure surfaces. The meteorological data were obtained from two automated weather stations located near the study sites. Solar radiation was corrected for terrain inclination and exposure surfaces, as it is measured based on the plane, perpendicularly to the vertical location. The LAI values collected in the field were used. For the comparative simulations in productivity variation, the mechanistic 3PG model was used, considering the relief exposure surfaces. It was verified that during most of the year, the southern surfaces showed lower availability of incident solar radiation, resulting in up to 66% losses, compared to the same surface considered plane, probably related to its geographical location and higher declivity. Higher values were obtained for the plantings located on the northern surface for the variables LAI, volume and mean annual wood increase, with this tendency being repeated in the 3PG model simulations.

Relative reduction in annual soil loss in micro watersheds due to the relief and forest cover

With the intense debate, in Brazil, between landowners and public agencies about the amount of area with forest cover needed in different regions, there is an increase of the need for provision of technical data used as a basis for decision making. One of the criteria to evaluate the effect of forest cover in protecting water resources is the soil loss, which leads to several consequences on the environment, including the silting of the rivers. Therefore, this study aimed to evaluate the reduction in the soil loss in micro watersheds with different reliefs, size and location of forest cover, in the Corumbataí River watershed, in the state of São Paulo, using the Revised Universal Soil Loss Equation (RUSLE) in a GIS environment. For this study, 18 watersheds in three degrees of slope were selected, and 20 scenarios for land-use were established, by analyzing the influence of the PPA size, and the size and the location of the Legal Reserve. The results showed that: a) the effect of forest cover in reducing annual soil loss varies depending on the average slope of the watershed; b) the PPA width must be determined taking into account the slope of the watershed; c) the Legal Reserve must be located along the PPA. These provide better results in reducing annual soil loss.

Floristic and structural variation of weeds in eucalyptus plantations as influenced by relief and time of year

The objective of this work was to analyze the floristic variation and phytosociological structure of weeds as influenced by relief and time of year in eucalyptus plantations in Santana do Paraíso and Guanhães - MG. The total area sampled for each locality was approximately 10 ± 3 hectares, comprising three types of relief: lowland, slope, and upper area. In each type of relief, 10 plots of 1 m² were sampled, corresponding to 30 plots per locality, where they were randomly allocated in a zigzag. The taxonomic identification was performed in four assessments, corresponding to the months of November and March, comprising two ratings each season, always at the same points, and geo-referenced using the Global Positioning System (GPS). A total of 3,893 individuals, 18 families and 61 species, were identified in Santana do Paraiso and a total of 1,166 individuals, 13 families and 58 species, in Guanhães. In both localities, the most representative families in terms of wealth were: Poaceae, Asteraceae, and Fabaceae. Galinsoga parviflora was the most abundant species. The Vernonia polyantes was identified only in the lowlands, while Arrabida florida was identified in the slope and upper area. On the other hand, Emilia coccinea, Sida rhombifolia, S. paniculatum and Spermacoce latifolia were common to all three environments. Commelina benghalensis was present only in the month of March, while G. parviflora was present only in the month of November. It was concluded that the floristic and phytosociological variation of weeds in eucalyptus plantations is influenced by the type of relief and time of year, which should guide the management practices used in the culture.

In vivo fluctuation of Tax, Foxp3, CTLA-4, and GITR mRNA expression in CD4+CD25+ T cells of patients with human T-lymphotropic virus type 1-associated myelopathy

HTLV-1 Tax expression exerts an inhibitory effect on the Foxp3 transcription factor in CD4+CD25+ T-regulatory cells (Treg). For a better understanding of the role of Tax mRNA in the gene expression of cellular markers we measured Tax, Foxp3, CTLA-4, GITR, TGF-β, and IL-10 mRNA in Treg cells of 50 patients with human T-lymphotropic virus type 1 (HTLV-1)-associated myelopathy/tropical spastic paraparesis (HAM/TSP; 27 women and 23 men; mean age: 56.7 years). The control group consisted of 23 non-infected subjects (12 women and 11 men) with a mean age of 51.3 years. Real-time PCR was used to measure mRNA of Tax proteins and several cellular markers of Treg function. Determinations revealed a high level of Tax mRNA in HAM/TSP (124.35 copies/100 CD4+CD25+ T cells). Foxp3, GITR, and CTLA-4 mRNA levels were lower in HAM/TSP patients (mean ± SD, 22.07 ± 0.78, 9.63 ± 0.36, and 4.54 ± 0.39, respectively) than in non-infected controls (47.15 ± 12.94, 22.14 ± 1.91, and 21.07 ± 2.31). Both groups had similar levels of TGF-β and IL-10. An inverse relationship was found between Tax levels and Foxp3, CTLA-4, and GITR levels. Conversely, there was a direct correlation between levels of Foxp3, GITR, and CTLA-4. Disease severity and evolution time did not correlate with Tax or Foxp3 levels. The present results suggest that Tax and Foxp3 mRNA vary with the same degree of disease severity in HAM/TSP patients. Tax fluctuations may affect CTLA-4 and GITR expression via the Foxp3 pathway, causing virus-induced dysfunction of CD4+CD25+ T cells in HAM/TSP patients.

Examining the side effects of sucrose for pain relief in preterm infants: a case-control study

Sucrose solution is recommended as relevant pain relief management in neonates during acute painful procedures; however, only a few studies have analyzed the potentially adverse effects of sucrose administration to preterm neonates. The goal of this study was to examine the potential side effects of sucrose for pain relief in preterm infants, assessing feeding and weight gain during hospitalization and their feeding patterns postdischarge. The study sample consisted of 43 preterm neonates divided into two groups: a sucrose group (SG, n=18) and a control group (CG, n=25) in which no sucrose was administered. The SG received 0.5 mL/kg 25% oral sucrose for 2 min prior to all acute painful procedures during three consecutive days. A prospective review of medical charts was performed for all samples. The study was done prior to implementation of the institutional sucrose guidelines as a routine service, and followed all ethical requirements. There were no statistically significant differences between groups in terms of weight gain, length of stay with orogastric tubes, and parenteral feeding. Postdischarge, infant nutritional intake included feeding human milk to 67% of the SG and 74% of the CG. There were no statistically significant differences between groups regarding human milk feeding patterns postdischarge. Neonate feeding patterns and weight gain were unaffected following the short-term use of sucrose for pain relief.