lnternational transfer pricing strategies for minimizing global income taxes

Optimal financiai strategies are criticai for long term survival in competitive international markets. Financial strategies pertaining to transfer pricing have become increasingly important as income tax authorities seek additional revenues through increased monitoring of company practices. In this first of two articles, optimal tax strategies are presented after reviewing the transfer pricing concept and the rationale underlying governments' increased focus on transfer pricing. In the second forthcoming article, we analyze the effect of government restrictions on optimal pricing strategies.

International transfer pricing restrictions: impact on corporate financial policy

Transfer pricing is a pervasive issue that presents significant tax savings potential concerning international enterprises. The authors discuss company incentives to manage transfer prices in an article appearing in the preceding issue of this journal. In response to these incentives, governments have increasingly enacted and enforced domestic restrictions on transfer prices. In this article, contemporary norms restricting transfer pricing are analyzed. The OEGO and US pricing standards are assessed and Brazil's recent application of these standards is considered. Transfer pricing methods are described and evidence of their use is presented. We conclude by describing an intercompany transfer pricing policy intended to facilitate internaI financiaI management and minimize externaI tax threats.

Taking the "cross" out of cross-cultural transfer of management practice

Multi-national enterprises often attempt to replicate successful management practices in "foreign" environments. However, such practices may be ethnocentric because they fit the assumptions, behaviors, expectations, and values of the home cultural environment. Unless the underlying assumptions are shared, transfer to a differing environment may fail. Even if the focus is shifted from cultural differences to implementation, implementation approaches may also be criticized as ethnocentric for the same reasons. In this article, a non-ethnocentric model is expanded and used to test the portability of one management practice, performance appraisal, from the USA to Brazil. This "Test of Portability" may help managers understand which management practices are portable, and, perhaps even more valuable, provide a rationale for adaptation or rejection.

XRCC3 THR241MET polymorphism influence on nuclear buds frequency in exposed to formaldehyde

Formaldehyde (FA), also known as formalin, formal and methyl aldehydes, is a colorless, flammable, strong-smelling gas. It has an important application in embalming tissues and that result in exposures for workers in the pathology anatomy laboratories and mortuaries. Occupational exposure to FA has been shown to induce nasopharyngeal cancer and has been classified as carcinogenic to humans (group 1) on the basis of sufficient evidence in humans and sufficient evidence in experimental animals. Manifold in vitro studies clearly indicated that FA is genotoxic. FA induced various genotoxic effects in proliferating cultured mammalian cells. The cytokinesis-block micronucleus (CBMN) assay was originally developped as an ideal system form easuring micronucleus (MN), however it can also be used to measure nucleoplasmic bridges (NBP) and nuclear buds (NBUD). Over the past decade another unique mechanism of micronucleus formation, known as nuclear budding has emerged. NBUDS is considered as a marker of gene amplification and/or altered gene dosage because the nuclear budding process is the mechanism by which cells removed amplified and/excess DNA.

Solid-state Marx based two-switch voltage modulator for the On-Line Isotope Mass Separator accelerator at the European Organization for Nuclear Research

A new circuit topology is proposed to replace the actual pulse transformer and thyratron based resonant modulator that supplies the 60 kV target potential for the ion acceleration of the On-Line Isotope Mass Separator accelerator, the stability of which is critical for the mass resolution downstream separator, at the European Organization for Nuclear Research. The improved modulator uses two solid-state switches working together, each one based on the Marx generator concept, operating as series and parallel switches, reducing the stress on the series stacked semiconductors, and also as auxiliary pulse generator in order to fulfill the target requirements. Preliminary results of a 10 kV prototype, using 1200 V insulated gate bipolar transistors and capacitors in the solid-state Marx circuits, ten stages each, with an electrical equivalent circuit of the target, are presented, demonstrating both the improved voltage stability and pulse flexibility potential wanted for this new modulator.

Genotoxicity biomarkers micronucleus, nucleoplasmic bridges and nuclear buds

The increase of mortality from cancer brought urgency in identification and validation of predictive markers of risk and therefore early diagnosis. There is evidence that cytogenetic biomarkers are positively correlated with risk of cancer, and this is validated by studies of cohort and case-control. Cytokinesis-blocked micronucleus (CBMN) assay is used extensively in molecular epidemiology, and can be considered as a “cytome” assay covering cell proliferation, apoptosis, necrosis and chromosomal changes. The chromosomal alterations most reported and studied by the CBMN are: micronucleus (MN), nucleoplasmic bridges (NPB) and nuclear buds (NBUDS). The use of the MN assay in biomonitoring studies had a large increase in the last 15 years and international projects such as the HUMN have helped to increase the applicability and reliability of these tests.

A medicina nuclear no diagnóstico dos tumores gastroenteropancreáticos

Objectivo do estudo - Demonstrar o contributo, essencial, que a Medicina Nuclear apresenta no diagnóstico dos Tumores Gastroenteropancreáticos e demonstrar a importância da precocidade diagnóstica recorrendo, maioritariamente, aos exames de medicina nuclear.

Virtual communities of practice: investigating motivations and constraints in the processes of knowledge creation and transfer

With accelerated market volatility, faster response times and increased globalization, business environments are going through a major transformation and firms have intensified their search for strategies which can give them competitive advantage. This requires that companies continuously innovate, to think of new ideas that can be transformed or implemented as products, processes or services, generating value for the firm. Innovative solutions and processes are usually developed by a group of people, working together. A grouping of people that share and create new knowledge can be considered as a Community of Practice (CoP). CoP’s are places which provide a sound basis for organizational learning and encourage knowledge creation and acquisition. Virtual Communities of Practice (VCoP's) can perform a central role in promoting communication and collaboration between members who are dispersed in both time and space. Nevertheless, it is known that not all CoP's and VCoP's share the same levels of performance or produce the same results. This means that there are factors that enable or constrain the process of knowledge creation. With this in mind, we developed a case study in order to identify both the motivations and the constraints that members of an organization experience when taking part in the knowledge creating processes of VCoP's. Results show that organizational culture and professional and personal development play an important role in these processes. No interviewee referred to direct financial rewards as a motivation factor for participation in VCoPs. Most identified the difficulty in aligning objectives established by the management with justification for the time spent in the VCoP. The interviewees also said that technology is not a constraint.

Virtual communities of practice: examining the motivations and constraints in their knowledge creation and knowledge transfer preocesses

Paper accepted for the OKLC 2009 - International Conference on Organizational Learning, Knowledge and Capabilities (26-28th, April 2009, Amsterdam, the Netherlands).

Viabilidade económica da implementação de um reactor nuclear para a produção de energia eléctrica em Portugal

O presente trabalho tem como objectivo avaliar economicamente e determinar a viabilidade da implementação de um reactor nuclear para produção de energia eléctrica. Faz-se uma abordagem a aspectos da energia nuclear no mundo e em particular a energia nuclear na união europeia, faz-se uma análise sobre a estrutura do sector nuclear em Espanha e o futuro da energia no mundo. É realizada uma análise sobre a energia nuclear em Portugal, são abordados aspectos como o planeamento energético, a localização da central nuclear, os recursos nacionais e internacionais, a inspecção e regulação nuclear e o impacto industrial. Por fim, faz-se uma análise sobre o mix energético português. Faz-se uma descrição do ciclo de combustível, isto é, um estudo a todas as fases pela qual o combustível nuclear passa desde a sua extracção, passando pela produção de energia e processamento dos resíduos. São descritos os principais componentes de uma central nuclear e o seu princípio de funcionamento. São analisados em detalhe os principais componentes de um reactor PWR (Objecto de estudo deste trabalho) e faz-se uma breve descrição de alguns modelos de reactores nucleares. É feita uma breve abordagem aos principais acidentes nucleares que ocorreram, e descrita a escala de ocorrências nucleares e as várias fases de desmantelamento de uma central. São apresentados os principais custos da central nuclear. Também é apresentado um estudo de viabilidade económica analisando três cenários diferentes e é apresentada uma análise de sensibilidade do VAL em função de algumas variáveis que têm grande influência na avaliação económica. São apresentadas as principais conclusões.

Study of the one dimensional and transient bioheat transfer equation: Multi-layer solution development and applications

: In this work we derive an analytical solution given by Bessel series to the transient and one-dimensional (1D) bioheat transfer equation in a multi-layer region with spatially dependent heat sources. Each region represents an independent biological tissue characterized by temperature-invariant physiological parameters and a linearly temperature dependent metabolic heat generation. Moreover, 1D Cartesian, cylindrical or spherical coordinates are used to define the geometry and temperature boundary conditions of first, second and third kinds are assumed at the inner and outer surfaces. We present two examples of clinical applications for the developed solution. In the first one, we investigate two different heat source terms to simulate the heating in a tumor and its surrounding tissue, induced during a magnetic fluid hyperthermia technique used for cancer treatment. To obtain an accurate analytical solution, we determine the error associated with the truncated Bessel series that defines the transient solution. In the second application, we explore the potential of this model to study the effect of different environmental conditions in a multi-layered human head model (brain, bone and scalp). The convective heat transfer effect of a large blood vessel located inside the brain is also investigated. The results are further compared with a numerical solution obtained by the Finite Element Method and computed with COMSOL Multi-physics v4.1 (c). (c) 2013 Elsevier Ltd. All rights reserved.

Agentes fitoquímicos como radio-sensibilizadores na terapêutica em medicina nuclear

Mestrado em Medicina Nuclear. Área de especialização: Radiofarmácia.

New mitochondrial and nuclear evidences support recent demographic expansion and an atypical phylogeographic pattern in the Spittlebug Philaenus spumarius (Hemiptera, Aphrophoridae)

Copyright: © 2014 Rodrigues et al. This is an open-access article distributed under the terms of the Creative Commons Attribution License, which permits unrestricted use, distribution, and reproduction in any medium, provided the original author and source are credited.

Actualities on Nuclear Medicine Applications in Sports Medicine

Aims: This paper aims to address some of the main possible applications of actual Nuclear Medicine Imaging techniques and methodologies in the specific context of Sports Medicine, namely in two critical systems: musculoskeletal and cardiovascular. Discussion: At the musculoskeletal level, bone scintigraphy techniques proved to be a mean of diagnosis of functional orientation and high sensibility compared with other morphological imaging techniques in the detection and temporal evaluation of pathological situations, for instance allowing the acquisition of information of great relevance in athletes with stress fractures. On the other hand, infection/inflammation studies might be of an important added value to characterize specific situations, early diagnose of potential critical issues – so giving opportunity to precise, complete and fast solutions – while allowing the evaluation and eventual optimization of training programs. At cardiovascular system level, Nuclear Medicine had proved to be crucial in differential diagnosis between cardiac hypertrophy secondary to physical activity (the so called "athlete's heart") and hypertrophic cardiomyopathy, in the diagnosis and prognosis of changes in cardiac function in athletes, as well as in direct - and non-invasive - in vivo visualization of sympathetic cardiac innervation, something that seems to take more and more importance nowadays, namely in order to try to avoid sudden death episodes at intense physical effort. Also the clinical application of Positron Emission Tomography (PET) has becoming more and more widely recognized as promising. Conclusions: It has been concluded that Nuclear Medicine can become an important application in Sports Medicine. Its well established capabilities to early detection of processes involving functional properties allied to its high sensibility and the actual technical possibilities (namely those related with hybrid imaging, that allows to add information provided by high resolution morphological imaging techniques, such as CT and/or MRI) make it a powerful diagnostic tool, claiming to be used on an each day higher range of clinical applications related with all levels of sport activities. Since the improvements at equipment characteristics and detection levels allows the use of smaller and smaller doses, so minimizing radiation exposure it is believed by the authors that the increase of the use of NM tools in the Sports Medicine area should be considered.