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.

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.

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.

Effect of the addition of wheat fiber and partial pork back fat on the chemical composition, texture and sensory property of low-fat bologna sausage containing inulin and oat fiber

The objective of this work was to study the effect of adding wheat fiber and partial pork back fat on the quality characteristics of bologna sausage. The compound central rotating design was used with treatments containing fixed levels of inulin (5%) and oat fiber (1%) and variable levels of wheat fiber (0-4%) and pork back fat (0-10%). The pH and protein were similar in all the treatments, the fat was lower than the control treatment and the moisture content was higher than the control treatment (CF) without fibers. The wheat fiber increased the hardness and reduced cohesiveness and scores were given for overall impression. We found that it was possible to prepare low-fat bologna sausage with the addition of 6.58% fiber (5% inulin, 1% oat fiber and 0.58% wheat fiber), whilst retaining good sensory acceptability, thus reducing the pork back fat levels by between 25 and 42.75%.

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.

Immanuel Kant on intellectual property

This text initially discusses the notion of intellectual property in Kant's philosophy and in the eighteenth century. Next, it restates the problem within a contemporary setting, taking into account the new technologies on reproduction of information.