Clarification of the Meaning of "Beneficial Owner" in the OECD Model Tax Convention: Comment on the April 2011 Discussion Draft

In April 2011, the OECD released an important discussion draft that is intended to clarify the meaning of the term "beneficial ownership" under articles 10, 11 and 12 of the OECD Model (2010). This article discusses these proposals and demonstrates that some refinement is necessary.

Similarity between the association factor of ribosomal subunits and the protein Stm1p from Saccharomyces cerevisiae

A ribosome association factor (AF) was isolated from the yeast Sacchharomyces cerevisiae. Partial amino acid sequence of AF was determined from its fragment of 25 kDa isolated by treating AF with 2-(2-nitrophenylsulfenyl)-3-methyl-3'-Bromoindolenine (BNPS-skatole). This sequence has a 86% identity to the product of the single-copy S. cerevisiae STM1 gene that is apparently involved in several events like binding to quadruplex and triplex nucleic acids and participating in apoptosis, stability of telomere structures, cell cycle, and ribosomal function. Here we show that AF and Stm1p share some characteristics: both bind to quadruplex and Pu triplex DNA, associates ribosomal subunits, and are thermostable. These observations suggest that these polypeptides belong to a family of proteins that may have roles in the translation process.

The meaning of dependence and independence of older people with a disability in Ireland

The paper presents the findings of a research study carried out in Ireland in 2006 (Murphy et al., 2007) which explored the meaning of dependence and independence for older people with a disability. The research adopted a grounded theory approach; purposive sampling was used initially with some relational sampling towards the latter interviews. The sample was comprised of 143 older people with one of six disabilities: stroke (n=20), arthritis (20), depression (20), sensory disability (20), a learning disability (24), and dementia (18). All participants lived at home, some participants required high levels of help in activities of living while others were mostly independent. An interview schedule was used to guide interviews, all of which were tape recorded and transcribed. Data was collected on levels of dependence and independence using the Katz scale. Participants recorded high levels of independence in relation to transferring (93%), toileting (92%), dressing (87%), continence (87%) and feeding (98%). The main area of dependence where participants required assistance from others was with bathing (77%). The constant comparative technique was used to analyze qualitative data. The findings of the study would suggest that participants personal definition of their independence or dependence shifted relative to others and/or improvement or worsening of their capacity People were aware of the difference between independence and dependence, but these two concepts were not always perceived as opposites. It was possible to be independent and dependent at the same time. People valued being able to do things for themselves, accepted help when necessary but wanted to reciprocate when possible. Participants used varied coping strategies to regain and retain control of their lives. Strategies to promote older peoples independence and self esteem will be explored in this paper.

Struggles for meaning and struggles for control: the diffusion of bandwagon technology in two institutional environments

In this thesis, I examine the diffusion process for a complex medical technology, the PET scanner, in two different health care systems, one of which is more market-oriented (Switzerland) and the other more centrally managed by a public agency (Quebec). The research draws on institutional and socio-political theories of the diffusion of innovations to examine how institutional contexts affect processes of diffusion. I find that diffusion proceeds more rapidly in Switzerland than in Quebec, but that processes in both jurisdictions are characterized by intense struggles among providers and between providers and public agencies. I show that the institutional environment influences these processes by determining the patterns of material resources and authority available to actors in their struggles to strategically control the technology, and by constituting the discursive resources or institutional logics on which actors may legitimately draw in their struggles to give meaning to the technology in line with their interests and values. This thesis illustrates how institutional structures and meanings manifest themselves in the context of specific decisions within an organizational field, and reveals the ways in which governance structures may be contested and realigned when they conflict with interests that are legitimized by dominant institutional logics. It is argued that this form of contestation and readjustment at the margins constitutes one mechanism by which institutional frameworks are tested, stretched and reproduced or redefined.

First-order molecular descriptors for molecular steric similarity

En aquest treball s'analitza la contribució estèrica de les molècules a les seves propietats químiques i físiques, mitjançant l'avaluació del seu volum i de la seva mesura de semblança, a partir d'ara definits com a descriptors moleculars de primer ordre. La difeèsncia entre aquests dos conceptes ha estat aclarida: mentre que el volum és la magnitud de l'espai que ocupa la molècula com a entitat global, la mesura de semblança ens dóna una idea de com està distribuïda la densitat electrònica al llarg d'aquest volum, i reflecteix més les diferències locals existents. L'ús de diverses aproximacions per a l'obtenció d'ambdós valors ha estat analitzat sobre diferents classes d'isòmers

Quantum similarity topological indices definition, analysis and comparison with classical molecular topological indices

Es mostra que, gracies a una extensió en la definició dels Índexs Moleculars Topològics, s'arriba a la formulació d'índexs relacionats amb la teoria de la Semblança Molecular Quàntica. Es posa de manifest la connexió entre les dues metodologies: es revela que un marc de treball teòric sòlidament fonamentat sobre la teoria de la Mecànica Quàntica es pot connectar amb una de les tècniques més antigues relacionades amb els estudis de QSPR. Es mostren els resultats per a dos casos d'exemple d'aplicació d'ambdues metodologies

Procedural Meaning Explicatures in the Development of New Subordination Strategies in Romance

The sociocultural changes that led to the genesis of Romance languages widened the gap between oral and written patterns, which display different discoursive and linguistic devices. In early documents, discoursive implicatures connecting propositions were not generally codified, so that the reader should furnish the correctinterpretation according to his own perception of real facts; which can still be attested in current oral utterances. Once Romance languages had undergone several levelling processes which concluded in the first standardizations, implicatures became explicatures and were syntactically codified by means of univocal new complexconjunctions. As a consequence of the emergence of these new subordination strategies, a freer distribution of the information conveyed by the utterances is allowed. The success of complex structural patterns ran alongside of the genesis of new narrative genres and the generalization of a learned rhetoric. Both facts are a spontaneous effect of new approaches to the act of reading. Ancient texts were written to be read to a wide audience, whereas those printed by the end of the XV th century were conceived to be read quietly, in a low voice, by a private reader. The goal of this paper is twofold, since we will show that: a) The development of new complex conjunctions through the history of Romance languages accommodates to four structural patterns that range from parataxis tohypotaxis. b) This development is a reflex of the well known grammaticalization path from discourse to syntax that implies the codification of discoursive strategies (Givón 2 1979, Sperber and Wilson 1986, Carston 1988, Grice 1989, Bach 1994, Blackemore 2002, among others]

Meaning of the λ parameter of skew–normal and log–skew normal distributions in fluid geochemistry

The literature related to skew–normal distributions has grown rapidly in recent yearsbut at the moment few applications concern the description of natural phenomena withthis type of probability models, as well as the interpretation of their parameters. Theskew–normal distributions family represents an extension of the normal family to whicha parameter (λ) has been added to regulate the skewness. The development of this theoreticalfield has followed the general tendency in Statistics towards more flexible methodsto represent features of the data, as adequately as possible, and to reduce unrealisticassumptions as the normality that underlies most methods of univariate and multivariateanalysis. In this paper an investigation on the shape of the frequency distribution of thelogratio ln(Cl−/Na+) whose components are related to waters composition for 26 wells,has been performed. Samples have been collected around the active center of Vulcanoisland (Aeolian archipelago, southern Italy) from 1977 up to now at time intervals ofabout six months. Data of the logratio have been tentatively modeled by evaluating theperformance of the skew–normal model for each well. Values of the λ parameter havebeen compared by considering temperature and spatial position of the sampling points.Preliminary results indicate that changes in λ values can be related to the nature ofenvironmental processes affecting the data

Classification of sags according to their origin based on the waveform similarity

A statistical method for classification of sags their origin downstream or upstream from the recording point is proposed in this work. The goal is to obtain a statistical model using the sag waveforms useful to characterise one type of sags and to discriminate them from the other type. This model is built on the basis of multi-way principal component analysis an later used to project the available registers in a new space with lower dimension. Thus, a case base of diagnosed sags is built in the projection space. Finally classification is done by comparing new sags against the existing in the case base. Similarity is defined in the projection space using a combination of distances to recover the nearest neighbours to the new sag. Finally the method assigns the origin of the new sag according to the origin of their neighbours

Practical applications of quantum molecular similarity measures (QMSM): programs and examples

Es descriu l'aproximació de Capes Atòmiques dins de la teoria de la Semblança Molecular Quàntica. Partint només de dades teòriques, s'ha trobat una relació entre estructura molecular i activitat biològica per a diversos conjunts de molècules. Es descriuen els aspectes teòrics de la Semblança Molecular Quàntica i alguns exemples d'aplicació

Statistical similarity between the compression of a porous material and earthquakes

It has been long stated that there are profound analogies between fracture experiments and earthquakes; however, few works attempt a complete characterization of the parallelisms between these so separate phenomena. We study the Acoustic Emission events produced during the compression of Vycor (SiO&sub&2&/sub&). The Gutenberg-Richter law, the modified Omori's law, and the law of aftershock productivity hold for a minimum of 5 decades, are independent of the compression rate, and keep stationary for all the duration of the experiments. The waiting-time distribution fulfills a unified scaling law with a power-law exponent close to 2.45 for long times, which is explained in terms of the temporal variations of the activity rate.

Multiple origins of invasive and "native" water frogs (Pelophylax spp.) in Switzerland

The marsh frog (Pelophylax ridibundus) has been introduced in many places of Central and Western Europe due to commercial trades with Eastern Europe, and is rapidly replacing the native pool frog (P. lessonae). A large number of Pelophylax species are distributed in Eastern Europe and the strong phenotypic similarity between these species is rendering their identification hazardous. Consequently, alien populations of Pelophylax might not strictly be composed of P. ridibundus as previously suspected. In the present study, we analyzed the cytochrome b and NADH dehydrogenase subunit 3 genes of introduced and native Pelophylax from Switzerland (299 individuals), in order to properly identify the source populations of the invaders and the genetic status of the native species. Our study highlighted the occurrence of several genetic lineages of invasive frogs in western Switzerland. Unexpectedly, we also showed that several populations of the native pool frog (P. lessonae) cluster with the Italian pool frog P. bergeri from central Italy (considered by some authors as a subspecies of P. lessonae) Hence, these populations are probably also the result of introductions, meaning that the number of native P. lessonae populations is less important than expected in Switzerland. These findings have important implications concerning the conservation of the endemic pool frog populations, as the presence of multiple alien species could strongly affect their long-term subsistence.