851 resultados para Tax avoidance


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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.

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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.

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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.

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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.

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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.

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Obtaining ecotoxicological data on pesticides in tropical regions is imperative for performing more realistic risk analysis, and avoidance tests have been proposed as a useful, fast and cost-effective tool. Therefore, the present study aimed to evaluate the avoidance behavior of Eisenia andrei to a formulated product, Vertimec(A (R)) 18 EC (a.i abamectin), in tests performed on a reference tropical artificial soil (TAS), to derive ecotoxicological data on tropical conditions, and a natural soil (NS), simulating crop field conditions. In TAS tests an adaptation of the substrate recommended by OECD and ISO protocols was used, with residues of coconut fiber as a source of organic matter. Concentrations of the pesticide on TAS test ranged from 0 to 7 mg abamectin/kg (dry weight-d.w.). In NS tests, earthworms were exposed to samples of soils sprayed in situ with: 0.9 L of Vertimec(A (R)) 18 EC/ha (RD); twice as much this dosage (2RD); and distilled water (Control), respectively, and to 2RD: control dilutions (12.5, 25, 50, 75%). All tests were performed under 25 +/- A 2A degrees C, to simulate tropical conditions, and a 12hL:12hD photoperiod. The organisms avoided contaminated TAS for an EC50,48h = 3.918 mg/kg soil d.w., LOEC = 1.75 mg/kg soil d.w. and NOEC = 0.85 mg/kg soil d.w. No significant avoidance response occurred for any NS test. Abamectin concentrations in NS were rather lower than EC50, 48h and LOEC determined in TAS tests. The results obtained contribute to overcome a lack of ecotoxicological data on pesticides under tropical conditions, but more tests with different soil invertebrates are needed to improve pesticides risk analysis.

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The major goal of this research was the development and implementation of a control system able to avoid collisions during the flight for a mini-quadrotor helicopter, based only on its embedded sensors without changing the environment. However, it is important to highlight that the design aspects must be seriously considered in order to overcome hardware limitations and achieve control simplification. The controllers of a UAV (Unmanned Aerial Vehicle) robot deal with highly unstable dynamics and strong axes coupling. Furthermore, any additional embedded sensor increases the robot total weight and therefore, decreases its operating time. The best balance between embedded electronics and robot operating time is desired. This paper focuses not only on the development and implementation of a collision avoidance controller for a mini-robotic helicopter using only its embedded sensors, but also on the mathematical model that was essential for the controller developing phases. Based on this model we carried out the development of a simulation tool based on MatLab/Simulink that was fundamental for setting the controllers' parameters. This tool allowed us to simulate and improve the OS4 controllers in different modeled environments and test different approaches. After that, the controllers were embedded in the real robot and the results proved to be very robust and feasible. In addition to this, the controller has the advantage of being compatible with future path planners that we are developing.

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Large areas of Amazonian evergreen forest experience seasonal droughts extending for three or more months, yet show maximum rates of photosynthesis and evapotranspiration during dry intervals. This apparent resilience is belied by disproportionate mortality of the large trees in manipulations that reduce wet season rainfall, occurring after 2-3 years of treatment. The goal of this study is to characterize the mechanisms that produce these contrasting ecosystem responses. A mechanistic model is developed based on the ecohydrological framework of TIN (Triangulated Irregular Network)-based Real Time Integrated Basin Simulator + Vegetation Generator for Interactive Evolution (tRIBS+VEGGIE). The model is used to test the roles of deep roots and soil capillary flux to provide water to the forest during the dry season. Also examined is the importance of "root niche separation," in which roots of overstory trees extend to depth, where during the dry season they use water stored from wet season precipitation, while roots of understory trees are concentrated in shallow layers that access dry season precipitation directly. Observational data from the Tapajo's National Forest, Brazil, were used as meteorological forcing and provided comprehensive observational constraints on the model. Results strongly suggest that deep roots with root niche separation adaptations explain both the observed resilience during seasonal drought and the vulnerability of canopy-dominant trees to extended deficits of wet season rainfall. These mechanisms appear to provide an adaptive strategy that enhances productivity of the largest trees in the face of their disproportionate heat loads and water demand in the dry season. A sensitivity analysis exploring how wet season rainfall affects the stability of the rainforest system is presented. Citation: Ivanov, V. Y., L. R. Hutyra, S. C. Wofsy, J. W. Munger, S. R. Saleska, R. C. de Oliveira Jr., and P. B. de Camargo (2012), Root niche separation can explain avoidance of seasonal drought stress and vulnerability of overstory trees to extended drought in a mature Amazonian forest, Water Resour. Res., 48, W12507, doi:10.1029/2012WR011972.

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

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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.

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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.

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Il presente lavoro parte dalla constatazione che l’Imposta sul valore aggiunto è stata introdotta con lo scopo specifico di tassare il consumo in modo uniforme a livello europeo. La globalizzazione dell’economia con l’abolizione delle frontiere ha tuttavia favorito la nascita non solo di un mercato unico europeo, ma anche di “un mercato unico delle frodi”. L’esistenza di abusi e frodi in ambito Iva risulta doppiamente dannosa per l’Unione europea: tali condotte incidono quantitativamente sull'ammontare delle risorse proprie dell’Unione e sulle entrate fiscali dei singoli Stati membri nonché violano il principio di concorrenza e producono distorsioni nel mercato unico. È in questo contesto che intervengono i giudici nazionali e la Corte di Giustizia, al fine di porre un freno a tali fenomeni patologici. Quest’ultima, chiamata a far rispettare il diritto comunitario, ha sviluppato una misura antifrode e antiabuso consistente nel diniego del diritto alla detrazione qualora lo stesso venga invocato dal soggetto passivo abusivamente o fraudolentemente. Vedremo però che il problema non può essere facilmente ridotto a formule operative: al di là dello schema, fin troppo scontato, dell’operatore apertamente disonesto e degli operatori con esso dichiaratamente correi, rimane il territorio grigio dei soggetti coinvolti, qualche volta inconsapevolmente qualche volta consapevolmente, ma senza concreta partecipazione nella frode da altri orchestrata. Permane a questo punto la domanda se sia coerente - in un sistema impositivo che privilegia i profili oggettivi, prescindendo, salvo gli aspetti sanzionatori, da quelli soggettivi- negare il diritto alla detrazione Iva per asserita consapevolezza di comportamenti fraudolenti altrui o se non vi siano regole più adatte al fine di porre un freno alle frodi e dunque più conformi al principio di proporzionalità.