Is the Spanish Inheritance and Gift Tax incompatible with the free movement of workers and capital?: The reasoned opinion of the EU Commission IP/10/513

The aim of my speech is answering to the question if the Spanish Inheritance and Gift Tax is incompatible with the free movement of workers and capital. We are going to pay special attention to the European Commission’s request to Spain to change its Inheritance and Gift Tax provisions for Non-Residents or Assets held abroad. In order to answer to the question mentioned above five points will be explained. At first place I am going to describe the infrengement procedure established in the Article 258 that the EU Commission can follow when a Member State doesn’t comply with Community Law. At second place, we are going to explain what is the content of the EU Commission delivered on 5th of may 2010 regarding the spanish Inheritance and Gift Tax. Then, we will analise what establishes the Community Law regarding the freedom of workers and capital and how they are understood by the EU Court of Justice in similar cases. Finally, we are going to provide possible amendments that Spain could undertake.

On estimation and identifiability issues of sex-linked inheritance with a case study of pigmentation in Swiss barn owl (Tyto alba)

Genetic evaluation using animal models or pedigree-based models generally assume only autosomal inheritance. Bayesian animal models provide a flexible framework for genetic evaluation, and we show how the model readily can accommodate situations where the trait of interest is influenced by both autosomal and sex-linked inheritance. This allows for simultaneous calculation of autosomal and sex-chromosomal additive genetic effects. Inferences were performed using integrated nested Laplace approximations (INLA), a nonsampling-based Bayesian inference methodology. We provide a detailed description of how to calculate the inverse of the X- or Z-chromosomal additive genetic relationship matrix, needed for inference. The case study of eumelanic spot diameter in a Swiss barn owl (Tyto alba) population shows that this trait is substantially influenced by variation in genes on the Z-chromosome (sigma(2)(z) = 0.2719 and sigma(2)(a) = 0.4405). Further, a simulation study for this study system shows that the animal model accounting for both autosomal and sex-chromosome-linked inheritance is identifiable, that is, the two effects can be distinguished, and provides accurate inference on the variance components.

Inheritance of Schistosoma mansoni infection incompatibility in Biomphalaria alexandrina snails

In this study, we looked at the inheritance of susceptibility and resistance to Schistosoma mansoni infection in the first generation of crossbred Biomphalaria alexandrina snails. Our ultimate goal is to use such information to develop a biological method of controlling schistosomiasis. We infected laboratory-bred snails with S. mansoni miracidia and examined cercarial shedding to determine susceptibility and resistance. Five parental groups were used: Group I contained 30 susceptible snails, Group II contained 30 resistant snails, Group III contained 15 susceptible and 15 resistant snails, Group IV contained 27 susceptible and three resistant snails and Group V contained three susceptible and 27 resistant snails. The percentage of resistant snails in the resulting progeny varied according to the ratio of susceptible and resistant parents per group; they are 7%, 100%, 68%, 45% and 97% from Groups I, II, III, IV and V, respectively. On increasing the percentage of resistant parent snails, the percentage of resistant progeny increased, while cercarial production in their susceptible progeny decreased.

Comprehensive analysis of Arabidopsis expression level polymorphisms with simple inheritance.

In Arabidopsis thaliana, gene expression level polymorphisms (ELPs) between natural accessions that exhibit simple, single locus inheritance are promising quantitative trait locus (QTL) candidates to explain phenotypic variability. It is assumed that such ELPs overwhelmingly represent regulatory element polymorphisms. However, comprehensive genome-wide analyses linking expression level, regulatory sequence and gene structure variation are missing, preventing definite verification of this assumption. Here, we analyzed ELPs observed between the Eil-0 and Lc-0 accessions. Compared with non-variable controls, 5' regulatory sequence variation in the corresponding genes is indeed increased. However, approximately 42% of all the ELP genes also carry major transcription unit deletions in one parent as revealed by genome tiling arrays, representing a >4-fold enrichment over controls. Within the subset of ELPs with simple inheritance, this proportion is even higher and deletions are generally more severe. Similar results were obtained from analyses of the Bay-0 and Sha accessions, using alternative technical approaches. Collectively, our results suggest that drastic structural changes are a major cause for ELPs with simple inheritance, corroborating experimentally observed indel preponderance in cloned Arabidopsis QTL.

Inheritance pattern and selection criteria for resistance to soybean cyst nematode races 3 and 9

The objective of this work was to determine soybean resistance inheritance to Heterodera glycines Ichinohe (soybean cyst nematode - SCN) races 3 and 9, as well as to evaluate the efficiency of direct and indirect selection in a soybean population of 112 recombinant inbred lines (RIL) derived from the resistant cultivar Hartwig. The experiment was conducted in a completely randomized design, in Londrina, PR, Brazil. The estimated narrow-sense heritabilities for resistance to races 3 and 9 were 80.67 and 77.97%. The genetic correlation coefficient (r g = 0.17; p<0.01) shows that some genetic components of resistance to these two races are inherited together. The greatest genetic gain by indirect selection was obtained to race 9, selecting to race 3 due to simpler inheritance of resistance to race 9 and not because these two races share common resistance genes. The resistance of cultivar Hartwig to races 3 and 9 is determined by 4 and 2 genes, respectively. One of these genes confers resistance to both races, explaining a fraction of the significant genetic correlation found between resistance to these SCN races. The inheritance pattern described indicates that selection for resistance to SCN must be performed for each race individually.

Inheritance of resistance to soybean cyst nematode races 3 and 14 in soybean RIL and F2 populations

The objective of this work was to evaluate the soybean inheritance of resistance to cyst nematode races 3 and 14. The following populations where evaluated: one population of recombinant inbred lines (RILs) [Hartwig (resistant) x Y23 (susceptible line)] for races 3, 14 and 9; one population of families F2:3 [M-SOY 8001 (resistant) x MB/BR 46 - Conquista (susceptible)] for race 3; and one population of families F2:3 [(S5995 (resistant) x BRSMG Renascença (susceptible)] for race 14. In RIL populations, four epistatic genes were identified which conditioned resistance to race 14, and three epistatic ones for resistance to races 3 and 9. The lack of one gene provided moderate resistance under all situations. The highest number of genes for resistance to race 14 points out that genes responsible for lower effects might be involved. In population F2:3 from M-SOY 8001 x MB/BR 46 - Conquista, one recessive gene for moderate resistance and two recessive genes complete resistance to race 3 were identified. Two recessive genes conditioning moderate resistance to race 14 were identified in population F2:3 from the crossing S5995 x BRSMG Renascença. These results will be useful in designing crossings, involving these parentals, with higher possibility to accumulating genes that provide resistance to several SCN races.

Inheritance of resistance to cotton blue disease

The objective of this work was to determine the inheritance of cotton blue disease resistance by cotton plants. Populations derived from the CD 401 and Delta Opal resistant varieties were evaluated, through a greenhouse test with artificial inoculation by viruliferous aphids. Cotton blue disease resistance is conditioned by one dominant gene, both in CD 401 and Delta Opal varieties.

Tomato plant inheritance of antixenotic resistance to tomato leafminer

The objective of this work was to determine the inheritance of resistance by antixenosis in tomato plants (Lycopersicon esculentum) to tomato leafminer [Tuta absoluta (Lepidoptera: Gelechiidae)]. Evaluations were performed for tomato plants of the generations P1, P2, F1, F2, RC1 and RC2. The measured characteristic in the parents, BGH-1497 (P2 male) and 'Santa Clara' (P1 female), and in the F1, F2, RC1 and RC2 generations was the number of eggs per plant. This number was converted to the oviposition nonpreference index. The inheritance of antixenosis resistance of genotype BGH-1497 is ruled by a gene of greater effect and polygenes in epistatic interactions, with a phenotypic proportion of 13:3 between susceptible and resistant genotypes, respectively.

Rift-related inheritance in orogens: a case study from the Austroalpine nappes in Central Alps (SE-Switzerland and N-Italy)

The Austroalpine nappe systems in SE-Switzerland and N-Italy preserve remnants of the Adriatic rifted margin. Based on new maps and cross-sections, we suggest that the complex structure of the Campo, Grosina/Languard, and Bernina nappes is inherited largely from Jurassic rifting. We propose a classification of the Austroalpine domain into Upper, Middle and Lower Austroalpine nappes that is new because it is based primarily on the rift-related Jurassic structure and paleogeography of these nappes. Based on the Alpine structures and pre-Alpine, rift-related geometry of the Lower (Bernina) and Middle (Campo, Grosina/Languard) Austroalpine nappes, we restore these nappes to their original positions along the former margin, as a means of understanding the formation and emplacement of the nappes during initial reactivation of the Alpine Tethyan margin. The Campo and Grosina/Languard nappes can be interpreted as remnants of a former necking zone that comprised pre-rift upper and middle crust. These nappes were juxtaposed with the Mesozoic cover of the Bernina nappe during Jurassic rifting. We find evidence for low-angle detachment faults and extensional allochthons in the Bernina nappe similar to those previously described in the Err nappe and explain their role during subsequent reactivation. Our observations reveal a strong control of rift-related structures during the subsequent Alpine reactivation on all scales of the former distal margin. Two zones of intense deformation, referred to as the Albula-Zebru and Lunghin-Mortirolo movement zones, have been reactivated during Alpine deformation and cannot be described as simple monophase faults or shear zones. We propose a tectonic model for the Austroalpine nappe systems that link inherited, rift-related structures with present-day Alpine structures. In conclusion, we believe that apart from the direct regional implications, the results of this paper are of general interest in understanding the control of rift structures during reactivation of distal-rifted margins.

Inheritance of seed coat color in sesame

The objective of this work was to determine the inheritance mode of seed coat color in sesame. Two crosses and their reciprocals were performed: UCLA37 x UCV3 and UCLA90 x UCV3, of which UCLA37 and UCLA90 are white seed, and UCV3 is brown seed. Results of reciprocal crosses within each cross were identical: F1 seeds had the same phenotype as the maternal parent, and F2 resulted in the phenotype brown color. These results are consistent only with the model in which the maternal effect is the responsible for this trait. This model was validated by recording the seed coat color of 100 F2 plants (F3 seeds) from each cross with its reciprocal, in which the 3:1 expected ratio for plants producing brown and white seeds was tested with the chi-square test. Sesame seed color is determined by the maternal genotype. Proposed names for the alleles participating in sesame seed coat color are: Sc1, for brown color; and Sc2, for white color; Sc1 is dominant over Sc2.

Inheritance of late flowering in natural variants of soybean cultivars under short-day conditions

The objective of this work was to determine the inheritance of the long juvenile period trait in natural variants of the Doko, BR 9 (Savana), Davis, Embrapa 1 (IAS 5RC), and BR 16 soybean cultivars. Complete diallel crosses were made between the Doko and BR 16 cultivars and their variants. A 3:1 segregation ratio was observed in the F2 populations of the 'Doko' x Doko-18T, 'Doko' x Doko-Milionária, 'Davis' x São Carlos, and 'BR 9 (Savana)' x MABR92-836 (Savanão) crosses, indicating that the long juvenile period trait is controlled by a pair of recessive genes. The difference in late flowering between the Doko cultivar and both of its variants was caused by a recessive spontaneous mutation at the same genetic locus. However, the variants Doko-18T and Doko-Milionária are identical mutants that share a pair of genes that control the long juvenile period under short-day conditions. These mutants can be used in breeding programs to develop cultivars adapted to low-latitude tropical regions.

Alleged Tax Competition: The Mysterious Death of Inheritance Taxes in Switzerland

Interjurisdictional competition over mobile tax bases is an easily understood mechanism, but actual tax-base elasticities are difficult to estimate. Political pressure for reducing tax rates could therefore be based on erroneous estimates of the mobility of tax bases. We show that tax competition provided the overwhelmingly dominant argument in the policy debates leading to a succession of reforms of bequest taxation by Swiss cantons. Yet, we find only very weak statistical evidence of a relationship between tax burdens on bequests and the concerned tax base of wealthy elderly individuals. Moreover, inheritance tax revenues are found to increase in inheritance tax rates even in the long run, and actual tax rates lie well below the revenue-maximising levels throughout. The alleged pressures of tax competition did not seem in reality to exist.

Sex-linked inheritance, genetic correlations and sexual dimorphism in three melanin-based colour traits in the barn owl.

Theory states that genes on the sex chromosomes have stronger effects on sexual dimorphism than genes on the autosomes. Although empirical data are not necessarily consistent with this theory, this situation may prevail because the relative role of sex-linked and autosomally inherited genes on sexual dimorphism has rarely been evaluated. We estimated the quantitative genetics of three sexually dimorphic melanin-based traits in the barn owl (Tyto alba), in which females are on average darker reddish pheomelanic and display more and larger black eumelanic feather spots than males. The plumage traits with higher sex-linked inheritance showed lower heritability and genetic correlations, but contrary to prediction, these traits showed less pronounced sexual dimorphism. Strong offspring sexual dimorphism primarily resulted from daughters not expressing malelike melanin-based traits and from sons expressing femalelike traits to similar degrees as their sisters. We conclude that in the barn owl, polymorphism at autosomal genes rather than at sex-linked genes generate variation in sexual dimorphism in melanin-based traits.