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.

Psychiatric patients' return for HIV/STI test results in mental health centers

OBJECTIVE: To assess individual and/or health service factors associated with patients returning for results of HIV or sexually transmitted infection (STI) tests in mental health centers. METHODS: Cross-sectional national multicenter study among 2,080 patients randomly selected from 26 Brazilian mental health centers in 2007. Multilevel logistic regression was used to assess the effect of individual (level 1) and mental health service characteristics (level 2) on receipt of test results. RESULTS: The rate of returning HIV/STI test results was 79.6%. Among health service characteristics examined, only condom distribution was associated with receiving HIV/STI test results, whereas several individual characteristics were independently associated including living in the same city where treatment centers are; being single; not having heard of AIDS; and not having been previously HIV tested. CONCLUSIONS: It is urgent to expand HIV/STI testing in health services which provide care for patients with potentially increased vulnerability to these conditions, and to promote better integration between mental health and health services.

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.

Rainfall erosivity and rainfall return period in the experimental watershed of Aracruz, in the coastal plain of Espirito Santo, Brazil

Knowledge on the factors influencing water erosion is fundamental for the choice of the best land use practices. Rainfall, expressed by rainfall erosivity, is one of the most important factors of water erosion. The objective of this study was to determine rainfall erosivity and the return period of rainfall in the Coastal Plains region, near Aracruz, a town in the state of Espírito Santo, Brazil, based on available data. Rainfall erosivity was calculated based on historic rainfall data, collected from January 1998 to July 2004 at 5 min intervals, by automatic weather stations of the Aracruz Cellulose S.A company. A linear regression with individual rainfall and erosivity data was fit to obtain an equation that allowed data extrapolation to calculate individual erosivity for a 30-year period. Based on this data the annual average rainfall erosivity in Aracruz was 8,536 MJ mm ha-1 h-1 yr-1. Of the total annual rainfall erosivity 85 % was observed in the most critical period October to March. Annual erosive rains accounted for 38 % of the events causing erosion, although the runoff volume represented 88 % of the total. The annual average rainfall erosivity return period was estimated to be 3.4 years.

Thidiazuron effects on shoot growth, return bloom, fruit set and nutrition of apples

Apple (Malus domestica Borkh.) trees, cultivars Gala and Fuji, were sprayed at full bloom with thidiazuron (TDZ) at doses of 0, 5, 10, or 20 g ha-1 of a.i. in order to evaluate its effects on plant growth and development, return bloom, fruit set, nutrition, and fruit yield. Fruit set increased with TDZ dose in 'Gala' but not in 'Fuji'. TDZ did not affect fruit yield in any cultivar. In 'Gala', the return bloom was reduced in about 50% at TDZ doses of 10 or 20 g ha-1. TDZ increased shoot growth in both cultivars. In leaves, TDZ decreased the concentration of Ca and Mg in 'Gala' and of Mg in 'Fuji', but did not affect the chlorophyll content, leaf area, length, width, and dry mass per cm² regardless of cultivar. In fruits, the effect of TDZ varied according to the portion evaluated. Highest doses of TDZ decreased the concentration of Ca and K in 'Gala' and of K in 'Fuji' in the entire fruits (flesh + skin); in the skin, highest doses of TDZ reduced the levels of N, Ca, and Mg in both cultivars, in addition to the level of K in 'Fuji'.

Factors associated with 56-day non-return rate in dairy cattle

The objective of this work was to identify factors associated with the 56-day non-return rate (56-NRR) in dairy herds in the Galician region, Spain, and to estimate it for individual Holstein bulls. The experiment was carried out in herds originated from North-West Spain, from September 2008 to August 2009. Data of the 76,440 first inseminations performed during this period were gathered. Candidate factors were tested for their association with the 56-NRR by using a logistic model (binomial). Afterwards, 37 sires with a minimum of 150 first performed inseminations were individually evaluated. Logistic models were also estimated for each bull, and predicted individual 56-NRR rate values were calculated as a solution for the model parameters. Logistic regression found four major factors associated with 56-NRR in lactating cows: age at insemination, days from calving to insemination, milk production level at the time of insemination, and herd size. First-service conception rate, when a particular sire was used, was higher for heifers (0.71) than for lactating cows (0.52). Non-return rates were highly variable among bulls. Asignificant part of the herd-level variation of 56-NRR of Holstein cattle seems attributable to the service sire. High correlation level between observed and predicted 56-NRR was found.

Inhibition of return, gap effect and saccadic reaction time to a visual target

Simple manual reaction time (MRT) to a visual target (S2) is shortened when a non-informative cue (S1) is flashed at the S2 location shortly before the onset of S2 (early facilitation). Afterwards, MRT to S2 appearing at the S1 location is lengthened (inhibition of return - IOR). Similar results have been obtained for saccadic reaction time (SRT). Moreover, when there is a temporal gap between offset of the fixation point (FP) and onset of a target (gap paradigm), SRT is shorter than SRT in an overlap paradigm (FP remains on). In the present study, we determined SRT to S2 (10º) after presenting S1 at the same eccentricity (10º) or at a parafoveal position (2º) in the same or in the opposite hemifield. In addition, we employed both gap and overlap paradigms. Twelve subjects were asked not to respond to S1 (2º or 10º) to the right or to the left of FP, but to respond by making a saccadic movement in response to S2. We obtained the following results: 1) a 40-ms gap effect, 2) an interaction between gap effect and IOR, 3) a 39-ms delay (IOR) when S2 appeared at the cued (S1) position, and 4) a smaller (17 ms) but significant inhibition when S1 occurred at 2º in the ipsilateral hemifield. Thus, a parafoveal (2º) S1 elicits an inhibition of SRT towards ipsilateral peripheral targets. Since an inhibition of the ipsilateral hemifield by a 1º eccentric cue has been reported to occur when manual responses are employed, we suggest that the postulated functional link between covert and overt orienting of attention is also valid for parafoveal cues.

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.

An evaluation of the 2003 tax reform effort in Brazil

This paper provides an assessment of the tax-reform effort launched by the newly elected Lula government in 2003. It analyzes how the envisaged reform had to be changed and scaled down, in the wake of strong political resistance, after a failed attempt to develop a consensual proposal, fully supported by state-governors. The main effective changes are then evaluated. Challenges ahead are discussed at the end.

A graphic explanation on how a tax on exports neutralizes the Dutch disease without costs to exporters

The adequate way of neutralizing the Dutch disease is the imposition of a variable tax on the export of the commodity that originates the disease. If such tax is equivalent to the "size" of the Dutch disease, it will shifts to the right its supply curve of the commodity in relation to the exchange rate, giving the existing domestic supply and the international demand, the exchange rate will depreciate at the value of the tax, and the equilibrium exchange rate will move from the "current" to the "industrial" equilibrium.