Financial strategies for minimizing corporate income taxes under Brazil's new global tax system

In 1996, Brazil adopted a worldwide income tax system for corporations. This system represents a fundamental change in how the Brazílian government treats multinational transactions and the tax minimizing strategies relevant to businesses. In this article, we describe the conceptual basis for worldwide tax systems and the problem of double taxation that they create. Responses to double taxation by both the governments and the priva te sector are considered. Namely, the imperfect mechanisms developed by Brazil and other countries for mitigating double taxation are analyzed. We ultimately focus on the strategies that companies utilize in order not only to avoid double texetion, but also to take advantage of tax havens.

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.

Designing competitive international compensation programs

Over the past 25 years, expatriate managers have voiced increased disenchantment with their compensation packages whíle abroad. This paper takes a prescriptive approach, outlíning severa I elements of a successful human resources strategy and stressing key ingredients of effective international compensation programs. Particular ettention is given to the adherence of cultural values and distrlbutive justice when working across nations and cultures.

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.

The undergraduate level (1st study cycle) as a fundamental platform/standard for the development of Urban and Regional Planning in higher education programs

LUDA is a research project of Key Action 4 "City of Tomorrow & Cultural Heritage" of the programme "Energy, Environment and Sustainable Development" within the Fifth Framework Programme of the European Commission

Monetary channels of social inclusion: a case study of basic income and the Caixa Econômica Federal in Brazil

This article reports evidence of new monetary channels for social inclusion involving basic income policies and the Caixa Econômica Federal, a Brazilian government savings bank. Since the Plano Real (Brazilian currency) and the liberalization of banking in the 1990s, the realization of competitive advantages by the Caixa as social policy agent and the importance of citizenship cards differ from existing theories of bank change, financial inclusion and monetary policy. Multi-method research reveals the importance of 1) political theories of basic income, 2) conceptions of citizenship and social justice, and 3) a back to the future modernization of government banking. This provides alternatives to contemporary market-based banking theory, neo-liberal policies, private and non-governmental microfinance strategies, and theories in political economy about fiscal constraints to social policies. New monetary channels of change also suggest that zero sum theories about politics, monetary authority and social inclusion are amiss.

Nutritional status of children of urban low-income communities, Brazil (1986)

During the second half of 1986 the health and nutritional status of 254 children aged up to six years was studied, as well as the socio-economic situation of their parents in two favelas (shantytowns) in Belo Horizonte, Brazil. The nutritional status of the children was characterized by stunting (Z-score: 20.1% < -2) but not by wasting (Z-score: 3.7% < -2). Consideration was also given to how far stunting was caused by high morbidity such as acute respiratory infections (point prevalence: 38.5%), diarrheal diseases (point prevalence: 11.5%) and parasitosis (point prevalence: 70.3%). Furthermore, anemia (point prevalence: 29.7%) appeared as another health problem. The most important determinant of anthropometric indices turned out to be the mother's schooling. From the present data it can be hypothesized that the nutritional status of the children was limited less by the lack of food than by their poor health status.

The impact of improvement of water supply and sanitation facilities on diarrhea and intestinal parasites: a Brazilian experience with children in two low-income urban communities

During the second half of 1986 the impact of the improvement of water supply and excreta disposal facilities on diarrheal diseases and intestinal parasitosis was studied in 254 children up to six years of age from two favelas (shanty towns) of Belo Horizonte, Brazil. The estimated incidence of diarrhea was 6.2 episodes/child year and the estimated period prevalence reached 31.0 episode days/ child/ year. The point prevalence of parasitosis was 70.7% (Ascaris lumbricoides: 55.4%, Trichuris trichiura: 19.6%, Giardia lamblia: 17.9%). The estimated prevalence of diarrhea decreased with improvement of water supply and sanitation facilities to 45% and 44% respectively, but no statistically significant impact was observed in the case of parasitosis. School education and weaning practice were found to be other important determinants of diarrhea.

Supplementary feeding programs: a critical analysis

A critical analysis of the Supplementary Feeding Programs which have been undertaken around the world is presented. Although only a few programs have been rigorously evaluated it seems that in relation to their main objectives, most of them have not proved to be successful. Some suggestions for improvement are put forward and the particular case of the Brazilian programs is assessed in detail.

Demographic profile and health conditions of the elderly in a community in an urban area of Southeastern Brazil

Some specific characteristics of the aging of the Brazilian population in different areas, states and communities all over the country, have shown significant variations. Historical series of demographic and health indicators for the population in their sixties and over in Brazil, state of S. Paulo and in the municipal district of Araraquara are listed as follows: level of education and urban population growth rate, income distribution, mortality rates and main causes of death. In 1991 the aged constituled were 7,8% of the Brazilian population and 9,7% in Araraquara community. The elderly population (of 70 years of aged and above) as a proportion of the whole, has increased and already stands for 40%. The same trend holds good for both the proportion of aged within the urban population and their level of education wich increased to 90% in 1991. The main causes of death are chronic degenerative diseases which have replaced the infectious illness: firts, the diseases of the circulatory sistem (which account for more than 40% of all deaths) and the neoplasms (which let to 15% of the deaths). On the basis of these health and demographic data relating to people of 60 years of age and over, this study suggests some procedures for the improvement of the quality of the assistance given to the target population: a) the assistance give to the aged should be improved by providing gerontological training for general physicians and nurses, both of public and private clinics; b) the already exixting educational activities for the aged, for health workers and for teachers of secundary education should be further developed; c) the number of day-hospitals should be increased for the purpose of avoiding unnecessary confinement so as maintain the low rate of institutionalization in homes for the elderly (0,7% in Araraquara). It is reported that at least 35% of the aged population in this area is entitled to private health assistance, wich brings out the importance of including such services in the local health programs for this group.

Developmental and evolutionary assumptions in a study about the impact of premature birth and low income on mother–infant interaction

In order to study the impact of premature birth and low income on mother–infant interaction, four Portuguese samples were gathered: full-term, middle-class (n=99); premature, middle-class (n=63); full-term, low income (n=22); and premature, low income (n=21). Infants were filmed in a free play situation with their mothers, and the results were scored using the CARE Index. By means of multinomial regression analysis, social economic status (SES) was found to be the best predictor of maternal sensitivity and infant cooperative behavior within a set of medical and social factors. Contrary to the expectations of the cumulative risk perspective, two factors of risk (premature birth together with low SES) were as negative for mother–infant interaction as low SES solely. In this study, as previous studies have shown, maternal sensitivity and infant cooperative behavior were highly correlated, as was maternal control with infant compliance. Our results further indicate that, when maternal lack of responsiveness is high, the infant displays passive behavior, whereas when the maternal lack of responsiveness is medium, the infant displays difficult behavior. Indeed, our findings suggest that, in these cases, the link between types of maternal and infant interactive behavior is more dependent on the degree of maternal lack of responsiveness than it is on birth status or SES. The results will be discussed under a developmental and evolutionary reasoning

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).

Virtual power players demand response programs management based on locational marginal prices

Power systems have been suffering huge changes mainly due to the substantial increase of distributed generation and to the operation in competitive environments. Virtual power players can aggregate a diversity of players, namely generators and consumers, and a diversity of energy resources, including electricity generation based on several technologies, storage and demand response. Resource management gains an increasing relevance in this competitive context, while demand side active role provides managers with increased demand elasticity. This makes demand response use more interesting and flexible, giving rise to a wide range of new opportunities.This paper proposes a methodology for managing demand response programs in the scope of virtual power players. The proposed method is based on the calculation of locational marginal prices (LMP). The evaluation of the impact of using demand response specific programs on the LMP value supports the manager decision concerning demand response use. The proposed method has been computationally implemented and its application is illustrated in this paper using a 32 bus network with intensive use of distributed generation.

A simulation tool for demand response programs implementation

The design and development of simulation models and tools for Demand Response (DR) programs are becoming more and more important for adequately taking the maximum advantages of DR programs use. Moreover, a more active consumers’ participation in DR programs can help improving the system reliability and decrease or defer the required investments. DemSi, a DR simulator, designed and implemented by the authors of this paper, allows studying DR actions and schemes in distribution networks. It undertakes the technical validation of the solution using realistic network simulation based on PSCAD. DemSi considers the players involved in DR actions, and the results can be analyzed from each specific player point of view.