Tax policy in Latin America: Assessment and guidelines for a second generation of reforms

Includes bibliography

Time to tax for inclusive growth

Safeguarding the advances the continent has already achieved and ensuring inclusive and sustainable growth must be a priority for all the countries in the region. That is why the Economic Commission for Latin America and the Caribbean (ECLAC) and Oxfam are committed to working together in order to promote and build a new consensus against inequality. There is no silver bullet, but there are measures that can be taken, which together can make a big difference —and tax reform is a good place to start. This publication has been prepared in the hope that it will contribute to efforts to combat inequality in Latin America, by analysing the fiscal challenges involved and proposing policy guidelines.

Caracterização petrográfica, química e tecnológica dos quartzitos do centro produtor de São Thomé das Letras no sudoeste do Estado de Minas Gerais

Pós-graduação em Geologia Regional - IGCE

Using Nebraska's Beginning Farmer Tax Credit Program

Many farm or ranch families that are attempting to bring a son or daughter back into their business experience a strain on the cash flow. Recent changes to Nebraska's Beginning Farmer Tax Credit Program provide an attractive incentive that can be very beneficial to those families. Regulation changes made in 2008 now allow parents to rent agricultural assets to their own children.

Using Nebraska’s Beginning Farmer Tax Credit Program

Many farm or ranch families that are attempting to bring a son or daughter back into their business experience a strain on the cash flow. After all, a business that has been providing enough income for one family to live on, must now not only generate adequate income for the parents living expenses, but also attempt to provide enough income for a second family, the successor. Recent changes to Nebraska’s Beginning Farmer Tax Credit Program provide an attractive incentive that can be very beneficial for family farming/ranching operations that are trying to bring a family member back into their business. Regulation changes made in 2008 now allow parents to rent agricultural assets to their own children.

RP97-43 Tax Planning When Buying or Selling a Farm

If you're like most farmers, one of your key goals is to maximize after-tax earnings. The more money left over after you've paid your farm bills land your taxes, the more you and your family will have to spend. You can increase thos enet earnings in sveral ways: by increasing production, by decreasing cost of supplies oer by finding a way to get more for your produce. But there's another way to increase your after-tax earnings. One that many farmers oculd afford to spen dmore time on: decreasing taxes. The key to avoiding unnecessary taxes is tax planning. This publication will help you do just that: plan for the future.

LTR point mutations in the Tax-responsive elements of HTLV-1 isolates from HIV/HTLV-1-coinfected patients

Background: In Virology Journal 2011, 8: 535, Neto et al. described point mutations into Tax-responsive elements (TRE) of the LTR region of HTLV-1 isolates from asymptomatic carriers from Sao Paulo, Brazil, and hypothesized that the presence of the G232A mutation in the TRE-1 increase viral proliferation and consequently the proviral load (PvL), while the A184G mutation in the TRE-2 do not have such effect. Findings: We performed the real-time PCR assay (pol) and sequenced LTR region of HTLV-1 isolates from 24 HIV/HTLV-1-coinfected patients without HTLV-1-associated diseases from the same geographic area. These sequences were classified as belonging to the transcontinental subgroup A of the Cosmopolitan subtype a. The frequency of G232A mutation (16/24, 66.7%) was high as much as 61.8% reported by Neto's in HTLV-1 asymptomatic carriers with high PvL. High frequency (13/24, 54.2%) of double mutations G232A and A184G was also detected in HIV/HTLV-1-coinfected patients. We did not quantify PvL, but comparative analyses of the cycle threshold (Ct) median values of the group of isolates presenting the mutated-types sequences (Ct 33.5, n = 16) versus the group of isolates with the wild-type sequences (Ct 32, n = 8) showed no statistical difference (p = 0.4220). Conclusion: The frequencies of mutated-type sequences in the TRE-1 and TRE-2 motifs were high in HIV/HTLV-1-coinfected patients from Sao Paulo, Brazil. If these LTR point mutations have predictive value for the development of HTLV-1-associated diseases or they correspond to the subtype of virus that circulate in this geographic area has to be determined.

Reproductive interference between two sibling species of gift-giving spiders

We investigated the possibility of reproductive interference between two sibling spider species, Paratrechalea azul and Paratrechalea ornata, which occur syntopically and reproduce synchronously. Males of both species offer a nuptial gift composed of prey wrapped in silk to females. Through laboratory experiments, we evaluated possible asymmetries in the outcome of heterospecific encounters between males and females, and investigated whether chemical signalling could function as a premating barrier between the two species. Males of P. azul were unable to discriminate conspecific from heterospecific female draglines, which resulted in wasted time and energy in nuptial gift construction. Males of P. ornata incurred a higher cost for discrimination mistakes because most of them were attacked by heterospecific females; 95% lost the nuptial gift upon the attack and 33% were preyed upon. This pattern is probably a consequence of differences in body size between males and females of each species. Both species showed erroneous female choice, but only P. ornata females courted heterospecific males, which are considerably larger than conspecific males and may resemble high-quality mating partners. Males of P. ornata also made discrimination mistakes, but at a much lower frequency compared to P. azul males. The selective pressure for precise recognition of conspecific female signs is probably stronger on P. ornata males because misdirected courtship may increase their chances of encountering predatory heterospecific females. This study provides the first detailed evidence of reproductive interference between two reproductively isolated spider species, showing that the costs paid by individuals of different sexes and different species are highly asymmetric. (C) 2012 The Association for the Study of Animal Behaviour. Published by Elsevier Ltd. All rights reserved.

Tax Gene Characterization of Human T-Lymphotropic Virus Type 1 Strains from Brazilian HIV-Coinfected Patients

The tax gene of human T-lymphotropic virus type 1 (HTLV-1) diverges among isolates according to geographic regions and has been classified into two genotypes: taxA and taxB. In Brazil, taxA is the most prevalent genotype in symptomatic and asymptomatic carriers. Few studies have been conducted in HIV-infected patients. The present study characterized the tax gene (1059 bp) in 13 Brazilian HIV-1/HTLV-1-coinfected patients from the south and southeast regions. The results confirmed the transcontinental HTLV-1 subgroup A of the Cosmopolitan subtype and showed high nucleotide similarity both among Brazilian sequences and in relation to the ATK prototype (99.5% and 99.2%, respectively). Six nucleotide substitutions were highly conserved among isolates, ranging from 76.9% to 100%: C7401T, T7914C, C7920T, C7982T, G8231A, and A8367C. The presence of the Brazilian molecular signature of genotype taxA was confirmed in all of the isolates, and they clustered into two Latin American clusters, which confirms the double introduction of HTLV-1 in Brazil.

CD3e expression in HTLV-1-infected individuals is associated with proviral load and Tax expression

Financial support: FUNDHERP, CTC, INCTC, FAPESP, CNPq and CAPES.

Tax Treaty Override

What exactly is tax treaty override ? When is it realized ? This thesis, which is the result of a co-directed PhD between the University of Bologna and Tilburg University, gives a deep insight into a topic that has not yet been analyzed in a systematic way. On the contrary, the analysis about tax treaty override is still at a preliminary stage. For this reason the origin and nature of tax treaty override are first of all analyzed in their ‘natural’ context, i.e. within general international law. In order to characterize tax treaty override and deeply understand its peculiarities the evaluation of the effects of general international law on tax treaties based on the OECD Model Convention is a necessary pre-condition. Therefore, the binding effects of an international agreement on state sovereignty are specifically investigated. Afterwards, the interpretation of the OECD Model Convention occupies the main part of the thesis in order to develop an ‘interpretative model’ which can be applied every time a case of tax treaty override needs to be detected. Fictitious income, exit taxes and CFC regimes are analyzed in order to verify their compliance with tax treaties based on the OECD Model Convention and establish when the relevant legislation realizes cases of tax treaty override.

Legal presumptions in national tax systems (Italy and Belgium) and in EU law

The thesis deals with the concept of presumptions, and in particular of legal presumptions, in the context of national tax systems (Italy and Belgium) and EU law. The purpose was to investigate the concept of legal presumption under a twofold comparative perspective. After having provided a general overview of the common core concept of presumption in the European context, an insight in the national approach to legal presumptions was given by examining two different national experiences, namely the Italian and Belgian tax systems. At this stage, the Constitutional framework and some of the most interesting and relevant at EU level presumptive measures were explored, with a view to underlining possible divergences and common grounds. The concept of (national) legal presumption was then investigated in the context of EU law, with the attempt to systematize under a uniform perspective a matter which has been traditionally dealt with either from the merely national point of view or, at EU level, through a fragmented form. In this instance, the EU law relevant framework and the most significant EUCJ case-law, in particular in the field of customs duties, VAT, on the issue of the repayment of taxes levied in breach of EU law and in the area of direct taxation, were examined so as to construe the overall EU approach to national legal presumptions. This was done with the finality of determining if and to what extent a common analytical framework may be identified, from which were extracted certain criteria governing the compatibility of national legal presumptions with EU law.

La fiscalità delle perdite dei gruppi transfrontalieri: tra regimi nazionali e libertà di stabilimento

Caratteristica comune ai regimi di consolidamento previsti dai diversi ordinamenti, è quella di consentire la compensazione tra utili e perdite di società residenti, e, di negare, o rendere particolarmente difficoltosa, la stessa compensazione, quando le perdite sono maturate da società non residenti. La non considerazione delle perdite comporta una tassazione al lordo del gruppo multinazionale, per mezzo della quale, non si colpisce il reddito effettivo dei soggetti che vi appartengono. L’effetto immediato è quello di disincentivare i gruppi a travalicare i confini nazionali. Ciò impedisce il funzionamento del Mercato unico, a scapito della libertà di stabilimento prevista dagli artt. 49-54 del TFUE. Le previsioni ivi contenute sono infatti dirette, oltre ad assicurare a società straniere il beneficio della disciplina dello Stato membro ospitante, a proibire altresì allo Stato di origine di ostacolare lo stabilimento in un altro Stato membro dei propri cittadini o delle società costituite conformemente alla propria legislazione. Gli Stati membri giustificano la discriminazione tra società residenti e non residenti alla luce della riserva di competenza tributaria ad essi riconosciuta dall’ordinamento europeo in materia delle imposte dirette, dunque, in base all’equilibrata ripartizione del potere impositivo. In assenza di qualsiasi riferimento normativo, va ascritto alla Corte di Giustizia il ruolo di interprete del diritto europeo. La Suprema Corte, con una serie di importanti pronunce, ha infatti sindacato la compatibilità con il diritto comunitario dei vari regimi interni che negano la compensazione transfrontaliera delle perdite. Nel verificare la compatibilità con il diritto comunitario di tali discipline, la Corte ha tentato di raggiungere un (difficile) equilibrio tra due interessi completamenti contrapposti: quello comunitario, riconducibile al rispetto della libertà di stabilimento, quello degli Stati membri, che rivendicano il diritto di esercitare il proprio potere impositivo.