950 resultados para Inheritance and transfer tax
Resumo:
In the beginning of the year 2007 there was a change in our taxation laws, allowing the use of partial division in business restructuring without any direct taxation consequences. In this literature research thesis, partial division and transfer of assets and their similarities and differences have been examined. In addition, the concept of branch of activity, which is closely related to partial division and transfer of assets, has been defined. The concept of branch of activity has changed over the years in the Central Tax Board rulings towards more allowing, taking the taxpayer’s opinions into consideration better. The definition of branch of activity can be made relatively flexibly as long as there is a valid commercial reason behind the restructuring. Partial division can be more usable in business restructuring than division, because the transferring company does not dissolve in partial division. Compared to transfer of assets, the advantage of partial division is the transfer of losses to the receiving company and the possibility to use cash payments.
Resumo:
Sixty-eight 10Be terrestrial cosmogenic nuclide (TCN) surface exposure ages are presented to define the timing of alluvial fan and strath terrace formation in the hyper-arid San Juan region of the Argentine Precordillera. This region is tectonically active, and numerous fault scarps traverse Quaternary landforms. The three study sites, Marquesado strath complex, Loma Negra alluvial fan and Carpintería strath complex reveal a history of alluvial fan and strath terrace development over the past w225 ka. The Marquesado complex Q3m surface dates to w17 3 ka, whereas the Loma Negra Q1ln, Q2ln, Q3ln, Q4ln, and Q5ln surfaces date to w24 3 ka, w48 2 ka, w65 13 ka, w105 21 ka, and w181 29 ka, respectively. The Carpintería complex comprises eight surfaces that have been dated and include the Q1c (w23 3 ka), Q2c (w5 5 ka), Q3ac (w25 12 ka), Q3bc (w29 15 ka), Q4c (w61 12 ka), Q5c (w98 18 ka), Q6c (w93 18 ka), and Q7c (w212 37 ka). 10Be TCN depth profile data for the Loma Negra alluvial fan complex and Carpintería strath terrace complex, as well as OSL ages on some Carpintería deposits, aid in refining surface ages for comparison with local and global climate proxies, and additionally offer insights into inheritance and erosion rate values for TCNs (w10 104 10Be atoms/g of SiO2 and w5 m Ma 1, respectively). Comparison with other alluvial fan studies in the region show that less dynamic and older preserved surfaces occur in the Carpintería and Loma Negra areas with only younger alluvial fan surfaces preserved both to the north and south. These data in combination with that of other studies illustrate broad regional agreement between alluvial fan and strath terrace ages, which suggests that climate is the dominant forcing agent in the timing of terrace formation in this region.
Resumo:
In this chapter, I shall discuss the genetics, mode of inheritance and molecular origin of several corneal dystrophies.
Resumo:
Members of the bacterial genus Streptomyces are well known for their ability to produce an exceptionally wide selection of diverse secondary metabolites. These include natural bioactive chemical compounds which have potential applications in medicine, agriculture and other fields of commerce. The outstanding biosynthetic capacity derives from the characteristic genetic flexibility of Streptomyces secondary metabolism pathways: i) Clustering of the biosynthetic genes in chromosome regions redundant for vital primary functions, and ii) the presence of numerous genetic elements within these regions which facilitate DNA rearrangement and transfer between non-progeny species. Decades of intensive genetic research on the organization and function of the biosynthetic routes has led to a variety of molecular biology applications, which can be used to expand the diversity of compounds synthesized. These include techniques which, for example, allow modification and artificial construction of novel pathways, and enable gene-level detection of silent secondary metabolite clusters. Over the years the research has expanded to cover molecular-level analysis of the enzymes responsible for the individual catalytic reactions. In vitro studies of the enzymes provide a detailed insight into their catalytic functions, mechanisms, substrate specificities, interactions and stereochemical determinants. These are factors that are essential for the thorough understanding and rational design of novel biosynthetic routes. The current study is a part of a more extensive research project (Antibiotic Biosynthetic Enzymes; www.sci.utu.fi/projects/biokemia/abe), which focuses on the post-PKS tailoring enzymes involved in various type II aromatic polyketide biosynthetic pathways in Streptomyces bacteria. The initiative here was to investigate specific catalytic steps in anthracycline and angucycline biosynthesis through in vitro biochemical enzyme characterization and structural enzymology. The objectives were to elucidate detailed mechanisms and enzyme-level interactions which cannot be resolved by in vivo genetic studies alone. The first part of the experimental work concerns the homologous polyketide cyclases SnoaL and AknH. These catalyze the closure of the last carbon ring of the tetracyclic carbon frame common to all anthracycline-type compounds. The second part of the study primarily deals with tailoring enzymes PgaE (and its homolog CabE) and PgaM, which are responsible for a cascade of sequential modification reactions in angucycline biosynthesis. The results complemented earlier in vivo findings and confirmed the enzyme functions in vitro. Importantly, we were able to identify the amino acid -level determinants that influence AknH and SnoaL stereoselectivity and to determine the complex biosynthetic steps of the angucycline oxygenation cascade of PgaE and PgaM. In addition, the findings revealed interesting cases of enzyme-level adaptation, as some of the catalytic mechanisms did not coincide with those described for characterised homologs or enzymes of known function. Specifically, SnoaL and AknH were shown to employ a novel acid-base mechanism for aldol condenzation, whereas the hydroxylation reaction catalysed by PgaM involved unexpected oxygen chemistry. Owing to a gene-level fusion of two ancestral reading frames, PgaM was also shown to adopt an unusual quaternary sturucture, a non-covalent fusion complex of two alternative forms of the protein. Furthermore, the work highlighted some common themes encountered in polyketide biosynthetic pathways such as enzyme substrate specificity and intermediate reactivity. These are discussed in the final chapters of the work.
Resumo:
Tutkielman tarkoituksena oli selvittää yksityisen osakeyhtiömuotoisen perheyrityksen sukupolvenvaihdoksenprosessin edullisuuteen ja onnistumiseen liittyviä tekijöitä. Tavoitteena oli selvittää, kuinka sukupolvenvaihdos tulee toteuttaa, jotta se olisi sekä luopujalle että jatkajalle mahdollisimman edullinen. Täten huomio kiinnittyi lahjaveroon, varainsiirtoveroon, luovutusvoittoveroon sekä mahdollisiin verohuojennuksiin. Lisäksi tutkielmassa kiinnitettiin huomiota sukupolvenvaihdoksen onnistumisen kannalta tärkeisiin pehmeisiin tekijöihin, joita ovat muun muassa luopumisen vaikeus ja vaihdoksen haasteet. Tutkielma toteutettiin laadullisena tapaustutkimuksena. Tutkimusaineistona toimivat case-yrityksen tilinpäätös sekä haastattelututkimuksen tulokset. Case-yrityksen sukupolvenvaihdoksen toteutustapojen edullisuutta mallinnettiin lahjanluonteisilla kaupoilla sekä lahjalla. Tulokset osoittivat, että case-yrityksen tapauksessa sukupolvenvaihdos tapahtuu edullisimmin lahjan avulla tai maksamalla 10 prosenttia yrityksen käyvästä arvosta. Tutkimus osoitti myös, että sukupolvenvaihdos on haastava ja aikaa vievä prosessi.
Resumo:
The study investigates organisational learning and knowledge acquisition of wood-based prefabricated building manufacturers. This certain group of case companies was chosen, because their management and their employees generally have a strong manufacturing and engineering background, while the housing sector is characterised by national norms, regulations, as well as local building styles. Considering this setting, it was investigated, how the case companies develop organisational learning capabilities, acquire and transfer knowledge for their internationalisation. The theoretical framework of this study constitutes the knowledge-based conceptualisation of internationalisation, which combines the traditional internationalisation process, as well as the international new venture perspective based on their commonalities in the knowledge-based view of the firm. Different theories of internationalisation, including the network-perspective, were outlined and a framework on organisational learning and knowledge acquisition was established. The empirical research followed a qualitative approach, deploying a multiple-case study with five case companies from Austria, Finland and Germany. In the study, the development of the wood-based prefabricated building industry and of the case companies are described, and the motives, facilitators and challenges for foreign expansion, as well as the companies’ internationalisation approaches are compared. Different methods of how companies facilitate the knowledge-exchange or learn about new markets are also outlined. Experience, market knowledge and personal contacts are considered essential for the internationalisation process. The major finding of the study is that it is not necessary to acquire the market knowledge internally in a slow process as proposed by the Uppsala model. In four cases companies engaged knowledge in symbiotic relations with local business partners. Thereby, the building manufacturers contribute their design and production capabilities, and in return, their local partners provide them with knowledge about the market and local regulations; while they manage the sales and construction operations. Thus, the study provides strong evidence for the propositions of network perspective. One case company developed the knowledge internally in a gradual process: it entered the market sequentially with several business lines, showing an increasing level of complexity. In both of the observed strategies, single-loop and double-loop learning processes occurred.
Resumo:
Litterfall and transfer of nutrients was estimated in two tropical coastal forests of Brazil - the Atlantic and the Restinga Forests at Cardoso Island, São Paulo. Samples were collected monthly, from June 1990 to May 1991, using thirty 0.25 m2 traps. There were significant differences in litter production between the Atlantic Forest (6.3 t.ha-1.year-1) and the Restinga Forest (3.9 t.ha-1.year-1). Litterfall was continuous throughout the year with maximum in the beginning of the rainy season in both sites. The annual return of mineral elements through litter in the Atlantic Forest was (kg.ha-1): 101.8 N, 3.8 P, 20.3 K, 60.0 Ca, 18.0 Mg, and 14.6 S and in the Restinga Forest was: 27.5 N, 1.0 P, 6.5 K, 30.0 Ca, 10.9 Mg, and 6.6 S. The return, although small, is relevant due to the low fertility of the soils in those ecosystems, especially in Restinga. The Restinga Forest seems to be an ecosystem well adapted to oligotrophic conditions, lying among those presenting higher nutrient use efficiency.
Resumo:
Toxic cyanobacteria are common in Portuguese freshwaters and the most common toxins are microcystins. The occurrence of microcystin-LR (MCYST-LR) has been reported since 1990 and a significant number of water reservoirs that are used for drinking water attain high levels of this toxin. Aquatic animals that live in eutrophic freshwater ecosystems may be killed by microcystins but in many cases the toxicity is sublethal and so the animals can survive long enough to accumulate the toxins and transfer them along the food chain. Among these, edible mollusks, fish and crayfish are especially important because they are harvested and sold for human consumption. Mussels that live in estuarine waters and rivers where toxic blooms occur may accumulate toxins without many significant acute toxic effects. In this study data are presented in order to understand the dynamics of the accumulation and depuration of MCYST-LR in mussels. The toxin is readily accumulated and persists in the shellfish for several days after contact. In the crayfish the toxin is accumulated mainly in the gut but is also cleared very slowly. In carps, although the levels of the toxins found in naturally caught specimens were not very high, some toxin was found in the muscle and not only in the viscera. This raises the problem of the toxin accumulation by fish and possible transfer through the food chain. The data gathered from these experiments and from naturally caught specimens are analyzed in terms of risk for human consumption. The occurrence of microcystins in tap water and the incidence of toxic cyanobacteria in fresh water beaches in Portugal are reported. The Portuguese National Monitoring Program of cyanobacteria is mentioned and its implications are discussed.
Resumo:
Glucokinase (GCK) is an enzyme that regulates insulin secretion, keeping glucose levels within a narrow range. Mutations in the glucokinase gene cause a rare form of diabetes called maturity-onset diabetes of the young (MODY). An early onset (less than 25 years), autosomal dominant inheritance and low insulin secretion stimulated by glucose characterize MODY patients. Specific insulin and proinsulin were measured in serum by immunofluorimetric assays (IFMA) during a 75-g oral glucose tolerance test (OGTT). Two kindreds (SA and LZ) were studied and compared to non-diabetic unrelated individuals (control group 1) matched for age and body mass index (BMI). In one kindred, some of these subjects were also obese (BMI >26 kg/m2), and other family members also presented with obesity and/or late-onset NIDDM. The MODY patients were also compared to a group of five of their first-degree relatives with obesity and/or late-onset NIDDM. The proinsulin profile was different in members of the two MODY kindreds. Fasting proinsulin and the proinsulin/insulin ratio were similar in MODY members of kindred LZ and subjects from control group 1, but were significantly lower than in MODY members of kindred SA (P<0.02 and P<0.01, for proinsulin and proinsulin/insulin ratio, respectively). Moreover, MODY members of family SA had higher levels of proinsulin and proinsulin/insulin ratio, although not significantly different, when compared to their first-degree relatives and to subjects from control group 2. In conclusion, we observed variable degrees of proinsulin levels and proinsulin/insulin ratio in MODY members of two different kindreds. The higher values of these parameters found in MODY and non-MODY members of kindred SA is probably related to the obesity and late-onset NIDDM background present in this family.
Resumo:
Effective control and limiting of carbon dioxide (CO₂) emissions in energy production are major challenges of science today. Current research activities include the development of new low-cost carbon capture technologies, and among the proposed concepts, chemical combustion (CLC) and chemical looping with oxygen uncoupling (CLOU) have attracted significant attention allowing intrinsic separation of pure CO₂ from a hydrocarbon fuel combustion process with a comparatively small energy penalty. Both CLC and CLOU utilize the well-established fluidized bed technology, but several technical challenges need to be overcome in order to commercialize the processes. Therefore, development of proper modelling and simulation tools is essential for the design, optimization, and scale-up of chemical looping-based combustion systems. The main objective of this work was to analyze the technological feasibility of CLC and CLOU processes at different scales using a computational modelling approach. A onedimensional fluidized bed model frame was constructed and applied for simulations of CLC and CLOU systems consisting of interconnected fluidized bed reactors. The model is based on the conservation of mass and energy, and semi-empirical correlations are used to describe the hydrodynamics, chemical reactions, and transfer of heat in the reactors. Another objective was to evaluate the viability of chemical looping-based energy production, and a flow sheet model representing a CLC-integrated steam power plant was developed. The 1D model frame was succesfully validated based on the operation of a 150 kWth laboratory-sized CLC unit fed by methane. By following certain scale-up criteria, a conceptual design for a CLC reactor system at a pre-commercial scale of 100 MWth was created, after which the validated model was used to predict the performance of the system. As a result, further understanding of the parameters affecting the operation of a large-scale CLC process was acquired, which will be useful for the practical design work in the future. The integration of the reactor system and steam turbine cycle for power production was studied resulting in a suggested plant layout including a CLC boiler system, a simple heat recovery setup, and an integrated steam cycle with a three pressure level steam turbine. Possible operational regions of a CLOU reactor system fed by bituminous coal were determined via mass, energy, and exergy balance analysis. Finally, the 1D fluidized bed model was modified suitable for CLOU, and the performance of a hypothetical 500 MWth CLOU fuel reactor was evaluated by extensive case simulations.
Resumo:
Epidemiological and case-controlled studies suggest that estrogen replacement therapy might be beneficial in terms of primary prevention of coronary heart disease (CHD). This beneficial effect of estrogens was initially considered to be due to the reduction of low density lipoproteins (LDL) and to increases in high density lipoproteins (HDL). Recent studies have shown that estrogens protect against oxidative stress and decrease LDL oxidation. Estrogens have direct effects on the arterial tissue and modulate vascular reactivity through nitric oxide and prostaglandin synthesis. While many of the effects of estrogen on vascular tissue are believed to be mediated by estrogen receptors alpha and ß, there is evidence for `immediate non-genomic' effects. The role of HDL in interacting with 17ß-estradiol including its esterification and transfer of esterified estrogens to LDL is beginning to be elucidated. Despite the suggested positive effects of estrogens, two recent placebo-controlled clinical trials in women with CHD did not detect any beneficial effects on overall coronary events with estrogen therapy. In fact, there was an increase in CHD events in some women. Mutations in thrombogenic genes (factor V Leiden, prothrombin mutation, etc.) in a subset of women may play a role in this unexpected finding. Thus, the cardioprotective effect of estrogens appears to be more complicated than originally thought and requires more research.
Resumo:
Kandidaatintutkielmani käsittelee Invoice-kauppaa ja sitä, mitä etuja siihen liittyy verrattuna tavanomaiseen tax-free kauppaan. Invoice-veronpalautusjärjestelmässä EU:n ulkopuolella asuva asiakas saa veronpalautuksen samasta liikkeestä seuraavalla asiointikerralla. Arvonlisäveronpalautukset on kuitenkin haettava puolen vuoden sisällä ostosten tekemisestä. Tavanomaisessa tax-free kaupassa asiakas saa arvonlisäveronpalautuksen rajalta poistuessaan Suomesta. Invoicea käytettäessä asiakas saa verosta isomman osan takaisin kuin tavanomaisessa tax-free kaupassa, mutta palautuksen saaminen kestää kauemmin, koska Invoicea käytettäessä veronpalautuksen voi saada vain samasta liikkeestä, missä ostokset on tehty. Tutkielmani tarkastelee aihetta kauppiaan näkökulmasta. Kauppiaan kannalta Invoicen etuna on erityisesti asiakkaiden ”koukuttaminen”, koska veronpalautukset on aina haettava samasta liikkestä, mistä tuotteet on ostettu. Näin samat asiakkaat tulevat usein samaan liikkeeseen myös seuraavilla Suomen matkoilla saadakseen veronpalautukset. Tämä tuo liikkeille usein myös uusia kanta-asiakkaita.Toisaalta on huomioitava myös Invoicen käytöstä kauppiaalle ja kassoille mahdollisesti aiheutuva lisätyö ja kustannukset. Veronpalautusten maksaminen takaisin asiakkaille ja tullissa leimattujen kuittien käsittely vie kassoilla tavanomaista enemmän aikaa ja saattaa vaatia lisää henkilökuntaa. Tutkielma on toteutettu laadullisena eli kvalitatiivisena ja tutkimusmenetelmänä on käytetty haastatteluita. Haastateltavat ovat kauppiaita Kaakkois-Suomen alueelta. Tavoitteenani oli koota mahdollisimman monipuolinen haastateltavien joukko sisältäen niin vaate- ja vapaa-ajan liikkeitä kuin sekatavara- ja päivittäistavarakauppoja. Teorialähteinä käytin yliopiston kirjastosta lainattuja kirjoja, LUT:in tietokantojen ja Edilex-tietokannan artikkeleita sekä Verohallinnon dokumentteja ja verkkojulkaisuja. Lisäksi olen hyödyntänyt tutkielmassani myös ajankohtaisia uutisia sekä erilaisten paikallis- ja aikakauslehtien artikkeleita. Tutkielmani johtopäätöksissä tulin siihen tulokseen, että kauppiaan kannalta edullisinta on käyttää samanaikaisesti sekä Invoicea että perinteistä, palautusliikeiden palveluja hyödyntävää tax-free järjestelmää. Tämä mahdollistaa liikkeille mahdollisimman laajan asiakasjoukon. Suomessa usein käyvät ostosmatkailijat suosivat yleensä Invoicea täysimääräisen veronpalautuksen vuoksi. Palautusliikkeet taas veloittavat asiakkaalle maksettavasta veronpalautuksesta oman palvelumaksunsa. Suomessa harvemmin vieraileville taas palautusliikkeiden palvelut ovat edullisempia, sillä veronpalautukset saa rajalta maasta poistuttaessa, eikä tarvitse palata samaan liikkeeseen puolen vuoden sisällä. Palautusliikkeiden etuna Invoiceen nähden on myös asioinnin vaivattomuus, sillä eri liikkeissä asioivat ostosmatkailijat saavat kaikista matkalla tekemistään ostoksista arvonlisäveronpalautuksensa yhdestä paikasta sen sijaan, että kävisivät hakemassa ne joka liikkeestä erikseen.
Resumo:
The purpose ofthis study was to explore the process oftherapeutic riding as an experiential and holistic approach to learning and recovery for people with disabilities as perceived by the providers oftherapeutic riding. To enhance the connection between theory and practice and to suggest future research, the researcher endeavoured to develop a theory that contributed to the knowledge base oftherapeutic riding, animal-assisted therapy and education, experiential education, and experiential therapy in addition to contributing to connections among them. This topic was investigated because ofthe lack ofresearch about the process of therapeutic riding, particularly from learning and a recovery perspective. Few studies have addressed how therapeutic riding outcomes are achieved or how the therapeutic riding process actually works. This study was identified as grounded theory using qualitative data through interviews and narrative reflections with therapeutic riding providers, a researcher's journal, field notes, and written documents. Grounded theory analysis was used to analyze the qualitative data. This consisted ofdoing open, axial, and selective coding. This study provided detailed descriptions ofthe research approach, researcher's involvement, participant and site selection, data collection and analysis, methodological assumptions and limitations, credibility established, and ethical considerations. The findings ofthe data analysis revealed the theme ofrelationships as central to the learning and recovery process oftherapeutic riding for people with disabilities. The significance ofthe team relationships, the horse and rider relationship, and the providers and rider relationship was found. The essential components ofthe learning and recovery process were presented in a diagram in the selective coding phase. Goals oftherapeutic riding included psycho-education; behavioural and social; physical; and equestrian. Parts ofthe process ofhow outcomes were achieved included motivation; "opens new doors;" risk; task analysis; control; communication; and environmental factors. Outcomes of therapeutic riding included independence and mobility; confidence; and transfer abilities or skills. The implications ofthese findings for theory, practice, and further research were also. explored.
Resumo:
Vagal baroreflex sensitivity (BRS) is a measure of short term blood pressure (BP) regulation through alterations in heart rate. Low BRS reflects impaired autonomic system regulation and has been found to be a surrogate marker for cardiovascular health. In particular, it has found to be associated with the pathogenesis of adult hypertension. However, only limited information exists as to the negative consequences of childhood BP on baroreflex function. The objective of this study was to investigate BRS in children with 2 different BP profiles while controlling for the effects of age, maturation, sex, and body composition. A preliminary subsample of 11-14 year-old children from the HBEAT (Heart Behavioural Environmental Assessment Team) Study was selected. The children were divided into 2 BP groups; high BP (HBP; 2:95tl1 percentile, n=21) and normal BP (NBP; <90th percentile, n=85). Following an initial 15 minutes of supine rest, 5 minutes of continuous beat-to-beat BP (Finapres) and RR interval (RRI) were recorded (standard ECG). Spectral indices were computed using Fast Fourier Transform and transfer function analysis was used to compute BRS. High frequency (HF) and low frequency (LF) power spectral areas were set to 0.15-0.4 Hz and 0.04-0.15 Hz, respectively. Body composition was measured using body mass index. After adjusting for body composition, maturation, age and sex ANCOV A results were as follows; LF and HF BRS, LF and HF RRI, and RRI total power were lower in the HBP versus NBP participants (p<0.05). As well, LF IHF SBP ratio was significantly higher in the HBP compared to the NBP group (p<0.05). The regression coefficients (unstandardized B) indicated that in changing groups (NBP to HBP) LF and HF BRS decreases by 4.04 and 6.18 ms/mmHg, respectively. Thus, as BP increases, BRS decreases. These data suggest that changes in autonomic activity occur in children who have HBP, regardless of age, sex, maturation, and body composition. Thus, despite their young age and relatively short amount of time having high BP compared with adults, these children are already demonstrating poor BP regulation and reduced cardiovagal activity. Given that childhood BP is associated with hypertension in adulthood, there is a growing concern in regards to the current cardiovascular health of our children and future adults.
Resumo:
EI Salvador presents an unfortunate history that includes a military regime and a civil war that together created a legacy of violence in which the country still struggle nowadays. Salud Escolar Integral (SEI) was created in 2005 as a program to combat youth violence throughout the re-formulation of physical education (PE) classes in public schools, promoting life skills learning that supports the resolution of conflicts with nonviolent ways. In 2007, SEI supported the creation of a physical e~ucation teacher education (PETE) degree at the Universidad Pedag6gica de EI Salvador (UPES), having the goal to assist pre-service teachers with a better understanding of humanistic principles. The present research analyzed if after attending all three years ofUPES PETE program, students presented high self-perception levels of competence and confidence related to attitude, skills and knowledge to teach PE within humanistic principles. Taking Personal and Social Responsibility (TPSR) was the theoretical framework used to analyze the development of humanistic principles. The study had a mixed-method longitudinal design that included questionnaires, reflection templates and interviews. In conclusion, although it is suggested that UPES should provide better support for the development of the teaching principles of empowering students and transfer learning, most of the humanistic principles were highly promoted by the program. At last, it is suggested that future research should track teachers' progress while teaching in schools, in order to analyze if the theory of promoting humanistic principles have also become a daily practice.