A nation's role in addressing base erosion and profit shifting : sovereignty in relation to transfer pricing

The notion of sovereignty is central to any international tax issue. While a nation is free to design its tax laws as it sees fit and raise revenue in accordance with the needs of its citizens, it is not possible to undertake such a task in isolation. Tax interactions between sovereign states cannot be avoided. Ultimately, the interactions mean that a nation must decide whether or engage in both collaboration and co ordination with other nations and supranational bodies alike or maintain a unilateral stance in relation to its tax policy. This article considers a modern conceptualisation of sovereignty to argue that a move towards a more unified approach to addressing international base erosion and profit sharing may be the ultimate exercise of national fiscal sovereignty.

Matrix metalloproteinase 13-deficient mice are resistant to osteoarthritic cartilage erosion but not chondrocyte hypertrophy or osteophyte development

Objective To investigate the role of matrix metalloproteinase 13 (MMP-13; collagenase 3) in osteoarthritis (OA). Methods OA was surgically induced in the knees of MMP-13-knockout mice and wild-type mice, and mice were compared. Histologic scoring of femoral and tibial cartilage aggrecan loss (0-3 scale), erosion (0-7 scale), and chondrocyte hypertrophy (0-1 scale), as well as osteophyte size (0-3 scale) and maturity (0-3 scale) was performed. Serial sections were stained for type X collagen and the MMP-generated aggrecan neoepitope DIPEN. Results Following surgery, aggrecan loss and cartilage erosion were more severe in the tibia than femur (P < 0.01) and tibial cartilage erosion increased with time (P < 0.05) in wild-type mice. Cartilaginous osteophytes were present at 4 weeks and underwent ossification, with size and maturity increasing by 8 weeks (P < 0.01). There was no difference between genotypes in aggrecan loss or cartilage erosion at 4 weeks. There was less tibial cartilage erosion in knockout mice than in wild-type mice at 8 weeks (P < 0.02). Cartilaginous osteophytes were larger in knockout mice at 4 weeks (P < 0.01), but by 8 weeks osteophyte maturity and size were no different from those in wild-type mice. Articular chondrocyte hypertrophy with positive type X collagen and DIPEN staining occurred in both wild-type and knockout mouse joints. Conclusion Our findings indicate that structural cartilage damage in a mouse model of OA is dependent on MMP-13 activity. Chondrocyte hypertrophy is not regulated by MMP-13 activity in this model and does not in itself lead to cartilage erosion. MMP-13 deficiency can inhibit cartilage erosion in the presence of aggrecan depletion, supporting the potential for therapeutic intervention in established OA with MMP-13 inhibitors.

Superior perilimbal epitheliopathy in recurrent corneal erosion syndrome

Purpose To highlight the finding of occult areas of poor epithelial adhesion in the superior perilimbal cornea in a minority of patients with recalcitrant recurrent corneal erosion syndrome presenting with corneal erosion elsewhere on the corneal surface. Patient population 31 eyes of 31 consecutive patients with corneal erosion undergoing mechanical debridement of the epithelium prior to diamond burr keratectomy for recurrent corneal erosion. Methods Determine the location and incidence of poor epithelial adhesion distant from the initial erosion by use of mechanical debridement with a dry microsponge. Results During debridement, 8 of 31 eyes (25.8%) displayed a large arcuate area of occult dysfunction of adhesion in the superior perilimbal area. None of these patients showed recurrence over a mean of 18 month after diamond burr keratectomy (95% confidence interval 0-36.9%). Conclusion Mechanical debridement with a microsponge identified a significant minority of patients with poor adhesion in the superior perilimbal cornea away from the area of obvious erosion and increased the target area for diamond burr keratectomy. This two pronged approach allowed successful management of this group.

Influence of pipe length and flow rate on nano-particle deposition in laminar circular pipe flows

The Lagrangian particle tracking provides an effective method for simulating the deposition of nano- particles as well as micro-particles as it accounts for the particle inertia effect as well as the Brownian excitation. However, using the Lagrangian approach for simulating ultrafine particles has been limited due to computational cost and numerical difficulties. The aim of this paper is to study the deposition of nano-particles in cylindrical tubes under laminar condition using the Lagrangian particle tracking method. The commercial Fluent software is used to simulate the fluid flow in the pipes and to study the deposition and dispersion of nano-particles. Different particle diameters as well as different pipe lengths and flow rates are examined. The results show good agreement between the calculated deposition efficiency and different analytic correlations in the literature. Furthermore, for the nano-particles with higher diameters and when the effect of inertia has a higher importance, the calculated deposition efficiency by the Lagrangian method is less than the analytic correlations based on Eulerian method due to statistical error or the inertia effect.

An investigation of Nano-particle deposition in cylindrical tubes under Laminar condition using Lagrangian transport model

Aerosol deposition in cylindrical tubes is a subject of interest to researchers and engineers in many applications of aerosol physics and metrology. Investigation of nano-particles in different aspects such as lungs, upper airways, batteries and vehicle exhaust gases is vital due the smaller size, adverse health effect and higher trouble for trapping than the micro-particles. The Lagrangian particle tracking provides an effective method for simulating the deposition of nano-particles as well as micro-particles as it accounts for the particle inertia effect as well as the Brownian excitation. However, using the Lagrangian approach for simulating ultrafine particles has been limited due to computational cost and numerical difficulties. In this paper, the deposition of nano-particles in cylindrical tubes under laminar condition is studied using the Lagrangian particle tracking method. The commercial Fluent software is used to simulate the fluid flow in the pipes and to study the deposition and dispersion of nano-particles. Different particle diameters as well as different flow rates are examined. The point analysis in a uniform flow is performed for validating the Brownian motion. The results show good agreement between the calculated deposition efficiency and the analytic correlations in the literature. Furthermore, for the nano-particles with the diameter more than 40 nm, the calculated deposition efficiency by the Lagrangian method is less than the analytic correlations based on Eulerian method due to statistical error or the inertia effect.

Studies on the Tracking and Erosion Resistance of RTV Silicone Rubber Nanocomposite

One of the problems associated with outdoor polymeric insulators is tracking and erosion of the weathershed which can directly influence the reliability of the power system. Flame retardants are added to the base material to enhance its tracking and erosion resistance. Hydroxide fillers are regarded as the best flame retardants. This paper deals with studies related to nano - sized magnesium dihydroxide (MDH) and micron-sized Alumina Trihydrate (ATH) fillers as flame retardants in RTV silicone rubber. Tracking and erosion resistance studies were carried out on MDH and ATH silicone rubber composites using an inclined plane tracking and erosion (IPT) resistance tester. The MDH filled (5% by wt) composites performed much better than ATH composites in terms of eroded mass, depth of erosion, width and length of erosion. The eroded mass of MDH composite is 49.8 % that of ATH composite which can be attributed to high surface area and higher thermal stability of MDH nanofillers.

Cavitation erosion characteristics of poly(methyl methacrylate) in a rotating disk device

Experimental results pertaining to the initiation, dynamics and mechanism of cavitation erosion on poly(methyl methacrylate) specimens tested in a rotating disk device are described in detail. Erosion normally starts at the location nearest to the center of rotation (CR). As the exposure time to cavitation increases, additional erosion areas or sites appear away from the CR and secondary erosion (induced by eroded pits) spreads upstream and merges with the main pit. The microcracks increase in density towards the end of the incubation period and transform into macrocracks in most cases. A study of light optical photographs and scanning electron micrographs of the eroded area shows that material particles are removed from the network of cracks because of crack joining and pits indicate particle debris. Optical degradation (loss of transmittance) is observed to be greater on the back of the specimen than on the front.

Spray erosion studies on pressed soil blocks

Erosion resistance of pressed soil blocks used for wall construction is discussed. The spray erosion test using a standardized shower spray is discussed. Spray erosion behaviour of pressed soil blocks made out of five different soils is presented. Results of laboratory and field tests are compared. Effect of clay content of the soil and density of the pressed soil block on erosion are discussed. Also the effect of water-proof coatings on erosion of soil blocks is presented. Erosion resistance of soil blocks stabilized with organic (jaggery syrup and starch) or inorganic binders is also discussed.

Laminar flow of a suspension in a curved pipe with varying curvature

The laminar flow of a fairly concentrated suspension (in which the volume fraction Z of the solid particles < 0.4) in a spatially varying periodically curved pipe has been examined numerically. Unlike the case of interacting suspension flows, the particles are found to flow in a well-mixed fashion, altering both the axial and circumferential velocities and consequently the fluid flux in the tube, depending on their diffusivity and inertia. The magnitude of shear stress at the wall is enhanced, suggesting that, if applied to vascular system, the vascular wall could be prone to ulceration during pathological situations like polycythemia. The delay in adaptation of the deviation in Poiseuille flow velocity to the curvature changes is also discussed in detail.

Unsteady laminar incompressible second-order boundary-layer flow at a three-dimensional stagnation point

The unsteadely laminar incompressible second-order boundary-layer flow at the stagnation point of a three-dimensional body has been studied for both nodal and saddle point regions. The effects of mass transfer and Prandtl number have been taken into account. The equations governing the flow have been solved numerically using an implicit finite-difference scheme. It has been found that the parameter characterizing the unsteadiness in the velocity of the free stream, the nature of the stagnation point, the mass transfer and Prandtl number strongly affect the second-order skin friction and heat transfer. The overall skin friction becomes less due to second-order effects but the heat transfer has the opposite behaviour. For large injection, the second-order skin-friction and heat-transfer results prevail over the first-order boundary layer results whereas for the case of large suction the behaviour is just the opposite.

A Novel Operator-Splitting Technique for One-Dimensional Laminar Premixed Flames

This paper is concerned the calculation of flame structure of one-dimensional laminar premixed flames using the technique of operator-splitting. The technique utilizes an explicit method of solution with one step Euler for chemistry and a novel probabilistic scheme for diffusion. The relationship between diffusion phenomenon and Gauss-Markoff process is exploited to obtain an unconditionally stable explicit difference scheme for diffusion. The method has been applied to (a) a model problem, (b) hydrazine decomposition, (c) a hydrogen-oxygen system with 28 reactions with constant Dρ 2 approximation, and (d) a hydrogen-oxygen system (28 reactions) with trace diffusion approximation. Certain interesting aspects of behaviour of the solution with non-unity Lewis number are brought out in the case of hydrazine flame. The results of computation in the most complex case are shown to compare very favourably with those of Warnatz, both in terms of accuracy of results as well as computational time, thus showing that explicit methods can be effective in flame computations. Also computations using the Gear-Hindmarsh for chemistry and the present approach for diffusion have been carried out and comparison of the two methods is presented.

Kinetics of Extraction of Iron(II1) by Bis(2-ethylhexyl Phosphate in a Laminar Liquid-Liquid Jet Reactor

The kinetics of iron(II1) extraction by bis(Zethylhexy1) phosphate (HDEHP, HA) in kerosene from sulfuric acid solutions has been studied in a liquid-liquid laminar jet reactor. The contact time of the interface in this reacting device is of the same order of magnitude as the surface renewal time in dispersion mixing and much less than that obtained in the relatively quiescent condition of the Lewis cell. Yet the analysis of the data in this study suggested a rate-controlling step involving surface saturation quite in conformity with that obtained in the Lewis cell and not with that in dispersion mixing as reported in the literature. Further, the mechanism suggested a weaker dependence of the rate on hydrogen ion concentration which was reported by other workers.

Genetic erosion and changes in distribution of sorghum (Sorghum bicolor L. (Moench)) landraces in north-eastern Ethiopia

Ethiopia is believed to be the centre of origin and domestication for sorghum, where sorghum remains one of the main staple crops. Loss of biodiversity is occurring at an alarming rate in Ethiopia and crops, including sorghum, have long been recognized as vulnerable to genetic erosion. A major collection of sorghum germplasm was made in 1973 by Gebrekidan and Ejeta from north-eastern Ethiopia. A new collection of landraces was made in 2003, and these were field evaluated at Sirinka in 2004 along with representative samples from the 1973 collection. Farmer surveys and soil and climate surveys were also performed. Preliminary analysis demonstrated that some important landraces have disappeared either locally or regionally in the past 30 years and many other landraces have become marginalized. Landraces which are less preferred in terms of agronomic value and end use, and introductions, have become increasingly important. Late maturing landraces were found to be particularly vulnerable, with a number disappearing altogether. Farmers have become more risk averse, and factors such as declining soil fertility, more frequent drought and unreliable rainfall, and increased pest infestation have contributed to a change in farmer landrace selection. Data are presented on the variability and unique characters of some of the Ethiopian landraces, and implications for conservation are discussed.

Estimation of Cavitation Erosion with Incubation Periods and Material Properties

A detailed study of the normalized correlations between the incubation period tc and the properties of various materials tested in a rotating disk device indicates that, at very high intensities, the strength properties influence the duration of tc. The analysis of extensive data from other laboratories for cavitation and liquid impingement erosion also indicates that, while both energy and strength properties influence the duration of tc, the latter ones predominate for a majority of cases. A fatigue-type failure occurs during tc. For estimating the time required to pierce a metallic specimen in a rotating device a relationship tp = 160 tc0.44 is proposed. A detailed study of normalized correlations between erosion resistance (inverse of erosion rate) and tc values of different materials tested in the rotating disk shows that correlations are good. Analysis of data from eight other investigators clearly points out the validity and the usefulness of this type of prediction.

Unsteady laminar compressible stagnation-point boundary-layer flow over a three-dimensional body: Higher order effects

The unsteady laminar compressible three-dimensional stagnation-point boundary-layer flow with variable properties has been studied when the velocity of the incident stream, mass transfer and wall temperature vary arbitrarily with time. The second-order unsteady boundary-layer equations for all the effects have been derived by using the method of matched asymptotic expansions. Both nodal and saddle point flows as well as cold and hot wall cases have been considered. The partial differential equations governing the flow have been solved numerically using an implicit finite-difference scheme. Computations have been carried out for an accelerating stream, a decelerating stream and a fluctuating stream. The results indicate that the unsteady free stream velocity distributions, the nature of the stagnation point, the mass transfer, the wall temperature and the variation of the density-viscosity product across the boundary significantly affect the skin friction and heat transfer. The variation of the wall temperature with time strongly affects the heat transfer whereas its effect is comparatively less on skin friction. Suction increases the skin friction and heat transfer but injection does the opposite. The skin friction in the x direction due to the combined effects of first- and second-order boundary layers is less than the skin-friction in the x direction due to the first-order boundary layers for all the parameters. The overall skin friction in the z direction and heat transfer are more or less than the first-order boundary layers depending upon the values of the various parameters.