B.T.A. memorandum decisions.

Title varies slightly.

Montgomery's Federal taxes.

Intended as a continuation of R. H. Montgomery's Income tax procedure, 1917- and related volumes

Winning Friends and Influencing People with Guns: Understanding the Growth of China's Military Diplomacy

Thesis (Ph.D.)--University of Washington, 2016-06

Endometrial and vaginal effects of low-dose estradiol delivered by vaginal ring or vaginal tablet

Aims The major aims of the study were to compare the safety of a continuous low-dose estradiol-releasing vaginal ring (ESTring) to that of a vaginal estradiol tablet (Vagifem®) on the endometrium and the relief of subjective symptoms and signs of urogenital estrogen deficiency. Quality of life and acceptability of treatment delivery were also assessed. Study design A prospective, randomized study in which women were assigned in a 2: 1 ratio to ESTring and Vagifem and followed for 12 months. The primary endpoint was endometrial safety, based on the results of ultrasound measurement of endometrial thickness and a progestogen challenge test at baseline and week 48. Efficacy was determined by subjective assessment of urogenital estrogen deficiency symptoms at baseline and weeks 3, 12, 24, 36 and 48 and assessment of signs of vaginal epithelial atrophy by the clinician at baseline, 12 and 48 weeks. In addition, pelvic floor strength, vaginal cytological evaluation and pH, bacteruria and patient acceptability were assessed. Quality of life was assessed using a menopause-specific quality-of-life questionnire and a 2-day bladder diary at baseline and 12 and 48 weeks. The comparability of the two groups was assessed using ANOVA, χ(2) or Fisher's exact tests. Results A total of 126 women were randomized to ESTring and 59 to Vagifem. There was no statistical difference between the groups in the alleviation of symptoms and signs of urogenital estrogen deficiency. Maturation indices increased in both groups, from generally atrophic at baseline to proliferative or highly proliferative at 48 weeks. After 48 weeks of treatment, there was no statistically significant difference in endometrial thickness between the two groups. A statistically smaller proportion of bleeding/spotting occurred in the ESTring group (n = 0) compared to the Vagifem users (n = 4). Estradiol and total estrone serum levels increased during treatment in both groups but remained within the normal postmenopausal range. General health status in both groups was unchanged but the urogenital component of health burden was significantly improved in both groups. Bladder diary variables showed no differences between treatment groups. Conclusion Equivalent endometrial safety and efficacy in the relief of the symptoms and signs of urogenital estrogen deficiency were demonstrated for the 12 months' use of a low-dose estradiol-releasing vaginal ring and a vaginal estradiol tablet.

Fiscal decentralization and development: An analysis of city governments in Argentina and Mexico, 1980--2010

This dissertation examines local governments' efforts to promote economic development in Latin America. The research uses a mixed method to explore how cities make decisions to innovate, develop, and finance economic development programs. First, this study provides a comparative analysis of decentralization policies in Argentina and Mexico as a means to gain a better understanding of the degree of autonomy exercised by local governments. Then, it analyzes three local governments each within the province of Santa Fe, Argentina and the State of Guanajuato, Mexico. The principal hypothesis of this dissertation is that if local governments collect more own-source tax revenue, they are more likely to promote economic development and thus, in turn, promote growth for their region. ^ By examining six cities, three of which are in Santa Fe—Rosario, Santa Fe (capital) and Rafaela—and three in Guanajuato—Leon, Guanajuato (capital) and San Miguel de Allende, this dissertation provides a better understanding of public finances and tax collection efforts of local governments in Latin America. Specific attention is paid to each city's budget authority to raise new revenue and efforts to promote economic development. The research also includes a large statistical dataset of Mexico's 2,454 municipalities and a regression analysis that evaluates local tax efforts on economic growth, controlling for population, territorial size, and the professional development. In order to generalize these results, the research tests these discoveries by using statistical data gathered from a survey administered to Latin American municipal officials. ^ The dissertation demonstrates that cities, which experience greater fiscal autonomy measured by the collection of more own-source revenue, are better able to stimulate effective economic development programs, and ultimately, create jobs within their communities. The results are bolstered by a large number of interviews, which were conducted with over 100 finance specialists, municipal presidents, and local authorities. The dissertation also includes an in-depth literature review on fiscal federalism, decentralization, debt financing and local development. It concludes with a discussion of the findings of the study and applications for the practice of public administration.^

Petroleum taxation contingent on counter-factual investment behaviour

ACKNOWLEDGMENTS We thank the referees for constructive suggestions. Thanks are due to Norwegian Research Council (Petrosam 2) for financial support.

Petroleum taxation contingent on counter-factual investment behaviour

ACKNOWLEDGMENTS We thank the referees for constructive suggestions. Thanks are due to Norwegian Research Council (Petrosam 2) for financial support.

Temporary contracts and non-protected employment in Argentina, Chile and Perú: incidence and determinants

The diverse kinds of legal temporary contracts and the employment forms that do not comply with legal requirements both facilitate employment adjustment to firms´ requirements and entail labour cost reductions. Their employment incidence depends not only on the economic and labour market evolutions but also on other factors, in particular the historical trajectories followed by labour legislation, state enforcement, and the degree of compliance. To contribute to the understanding of the determinants of the degree of utilization of different employment practices, the study reported in this article explores the use made of the various legal temporary contracts and of precarious employment relationships by private enterprises in three Latin American countries (Argentina, Chile and Peru) during 2003-2012, a period of economic growth, and the explanatory role of diverse factors.

El multilateralismo como intervencionismo. Estados Unidos y la Sociedad de Naciones en América Latina (1930-1946)

Este artículo analiza una dinámica de intervenciones de Estados Unidos en América Latina que no ha atraído suficientemente la atención de los historiadores. En los años treinta y cuarenta, cuando Europa se hundía en una nueva confrontación bélica, ciertos sectores del gobierno y del mundo empresarial norteamericano intentaron articular una nueva relación con los países del continente basada en una propuesta de multilateralismo que se había configurado dentro de la Sociedad de Naciones (SN). Estos estadounidenses intentaron establecer una dinámica de relaciones triangulares con los gobiernos latinoamericanos y los organismos técnicos de la SN. Gracias a ello, como se mostrará en este artículo para el caso del funcionamiento del Comité Fiscal de la Sociedad de Naciones, los latinoamericanos fueron capaces de influir en el tipo de políticas que debían emanar de esta relación triangular. La importancia de esta historia no es menor. La relación triangular entre Estados Unidos, América Latina y la SN sirvió de base para la reconstrucción de la gobernanza global liderada por los Estados Unidos tras la guerra.

Resident perceptions of natural resources between cities and across scales in the Pacific Northwest

As the global population becomes increasingly urban, research is needed to explore how local culture, land use, and policy will influence urban natural resource management. We used a broad-scale comparative approach and survey of residents within the Portland (Oregon)-Vancouver (Washington) metropolitan areas, USA, two states with similar geographical and ecological characteristics, but different approaches to land-use planning, to explore resident perceptions about natural resources at three scales of analysis: property level (“at or near my house”), neighborhood (“within a 20-minute walk from my house”), and metro level (“across the metro area”). At the metro-level scale, nonmetric multidimensional scaling revealed that the two cities were quite similar. However, affinity for particular landscape characteristics existed within each city with the greatest difference generally at the property-level scale. Portland respondents expressed affinity for large mature trees, tree-lined streets, public transportation, and proximity to stores and services. Vancouver respondents expressed affinity for plentiful accessible parking. We suggest three explanations that likely are not mutually exclusive. First, respondents are segmented based on preferences for particular amenities, such as convenience versus commuter needs. Second, historical land-use and tax policy legacies may influence individual decisions. Third, more environmentally attuned worldviews may influence an individual’s desire to produce environmentally friendly outcomes. Our findings highlight the importance of acknowledging variations in residents’ affinities for landscape characteristics across different scales and locations because these differences may influence future land-use policies about urban natural resources.

Planeamento Fiscal nas operações relativas a instrumentos financeiros derivados e a sua tributação

Mestrado em Fiscalidade

A tributação dos residentes não habituais: o caso português

No ano de 2009, foi introduzido no ordenamento jurídico português um regime de tributação privilegiado com vista a atrair estrangeiros de elevado valor acrescentado, promovendo o investimento e aumentando a qualificação da mão-de-obra. Apesar de não se tratar de uma experiência pioneira no domínio da tributação, assume-se verdadeiramente competitivo face aos restantes regimes em vigor na União Europeia, nomeadamente quanto ao âmbito e critérios de aplicação, bem como quanto à sua duração. A inevitável interação deste regime com as Convenções para evitar a Dupla Tributação e com o princípio da não discriminação, conduz-nos numa análise transversal que permita efetuar uma avaliação global e sistematizada dos benefícios que lhe estão subjacentes. Verifica-se que os eventuais constrangimentos com as Convenções para evitar a Dupla Tributação apesar de reais e de difícil eliminação resultam, por vezes, em situações bastante favoráveis para os seus beneficiários, como acontece com a dupla isenção concedida às pensões de fonte estrangeira. Complementarmente, consideramos que o facto de configurar um verdadeiro benefício fiscal, promovendo uma derrogação do regime regra da tributação em IRS, não compromete o princípio constitucional da não discriminação.

The Scottish Parliament in the 15th and 16th centuries

Earlier histories of the Scottish parliament have been somewhat constitutional in emphasis and have been exceedingly critical of what was understood to be parliament's subservience to the crown. Estimates by constitutional historians of the extreme weakness of parliament rested on an assessment of the constitutional system. The argument was that many of its features were not consistent with a reasonably strong parliament. Because the 'constitution' is apparently fragmented, with active roles played by bodies such as the lords of articles, the general council and the convention of estates, each apparently suggesting that parliament was inadequate, historians have sometimes failed to appreciate the positive role played by the estates in the conduct of national affairs. The thesis begins with a discussion of the reliability of the printed text of APS and proceeds to an examination of selected aspects of the work of parliament in a period from c 1424-c 1625. The belief of constitutional historians such as Rait that conditions In Scotland proved unfavourable to the interests and. effectiveness of parliament in the fifteenth and sixteenth centuries, is also examined. Chapter 1 concludes that APS is a less than reliable text, particularly for the reign of James I. Numerous statutes were excluded from the printed text and they are offered below for the first time. These statutes have been a useful addition to our understanding of the reign of James I. Chapter 2 analyses the motives behind the schemes for shire representation and concludes that neither constitutional theory nor political opportunism explains the support which James I and James VI gave to these measures. Both these monarchs were motivated by the realisation that their particular ambitions were dependent on winning the support of the estates whose ranks should include representatives from the shires. Chapter 3 examines the method of electing the lords of articles, the composition of this committee, and some aspects of its operation. The conclusion is that in the main the estates were the deciding force in the choice of the lords of articles. The committee's composition was more a reflection of a desire for a balance between representatives from north and south of the Forth and for the most important burghs and clergy to be selected than an attempt at electing government favourites. The articles did exercise a significant control over the items which came before parliament but this control was not absolute and applied to government as well as private legislation. Chapter 4 questions the traditional view that the general council and convention of estates were the same body. It is argued that they were two different institutions with different powers, but that they nevertheless worked within certain limits and were careful not to usurp the authority of parliament. Chapter 5 concedes that taxation was sometimes decided outside parliament; that the irregularity of taxation certainly weakened the bargaining power of the estates and that the latter did not appear to capitalise on these occasions when taxation was an issue. But the tendency was to ensure that, whether in or out of parliament, the decision to impose taxation was taken by a large number of each estate. The infrequency of taxation was a direct consequence of an unwillingness among the estates to agree to a regular taxation and their preference to ensure for the crown an alternative source of income. Moreover taxation was one issue, which more than any other, would be subject to contentious opposition by the estates, and could lead to the crown's defeat. Chapter 6 is concerned with ecclesiastical representation after the Reformation and the church's attitudes to the possibility of ministerial representation. Some ministers had doctrinal misgivings but the majority came to believe that the church's absence from parliament bad severely reduced. the influence of the church. That no agreement was forthcoming on a system of ministerial representation, particularly after 1597, is attributable to the estates' unwillingness to compromise and, not to the strength of opposition in the church. Chapter 7 examines the institutions which are sometime seen as 'rivals' of parliament and concludes that institutions such as the privy council were generally very careful in matters which needed the approval of parliament, and seemed aware of the greater authority of parliament. Chapter 8 which illustrates how parliament had the right to be consulted in all important matters of state, brings together the main points of the earlier chapters and offers further illustrations of the essential role which parliament played in the conduct of national affairs. Whether or not the system can be regarded as constitutionally sound, the estates in Scotland could observe parliament's day-to-day operation with some satisfaction. All in all, there is little convincing evidence that parliament was as weak as some historians would have us believe.

Location analysis of city sections: socio-demographic segmentation and restaurant potentiality estimation : a case study of Lisbon

One of the objectives of this study is to perform classification of socio-demographic components for the level of city section in City of Lisbon. In order to accomplish suitable platform for the restaurant potentiality map, the socio-demographic components were selected to produce a map of spatial clusters in accordance to restaurant suitability. Consequently, the second objective is to obtain potentiality map in terms of underestimation and overestimation in number of restaurants. To the best of our knowledge there has not been found identical methodology for the estimation of restaurant potentiality. The results were achieved with combination of SOM (Self-Organized Map) which provides a segmentation map and GAM (Generalized Additive Model) with spatial component for restaurant potentiality. Final results indicate that the highest influence in restaurant potentiality is given to tourist sites, spatial autocorrelation in terms of neighboring restaurants (spatial component), and tax value, where lower importance is given to household with 1 or 2 members and employed population, respectively. In addition, an important conclusion is that the most attractive market sites have shown no change or moderate underestimation in terms of restaurants potentiality.

Carbon reduction activism in the UK: lexical creativity and lexical framing in the context of climate change

This article examines discourses associated with a new environmental movement, “Carbon Rationing Action Groups” (CRAGs). This case study is intended to contribute to a wider investigation of the emergence of a new type of language used to debate climate change mitigation. Advice on how to reduce one's “carbon footprint,” for example, is provided almost daily. Much of this advice is framed by the use of metaphors and “carbon compounds”—lexical combinations of at least two roots—such as “carbon finance” or “low carbon diet.” The study uses a combination of tools from frame analysis and lexical pragmatics within the general framework of ecolinguistics to compare and contrast language use on the CRAGs' website with press coverage reporting on them. The analysis shows how the use of such lexical carbon compounds enables and facilitates different types of metaphorical frames such as dieting, finance and tax paying, war time rationing, and religious imperatives in the two corpora.