lnternational transfer pricing strategies for minimizing global income taxes

Optimal financiai strategies are criticai for long term survival in competitive international markets. Financial strategies pertaining to transfer pricing have become increasingly important as income tax authorities seek additional revenues through increased monitoring of company practices. In this first of two articles, optimal tax strategies are presented after reviewing the transfer pricing concept and the rationale underlying governments' increased focus on transfer pricing. In the second forthcoming article, we analyze the effect of government restrictions on optimal pricing strategies.

CROSS-COUNTRY STUDY ON THE DETERMINANTS OF BANK FINANCIAL DISTRESS

ABSTRACTBank failures affect owners, employees, and customers, possibly causing large-scale economic distress. Thus, banks must evaluate operational risks and develop early warning systems. This study investigates bank failures in the Organization for Economic Co-operation and Development, the North America Free Trade Area (NAFTA), the Association of Southeast Asian Nations, the European Union, newly industrialized countries, the G20, and the G8. We use financial ratios to analyze and explore the appropriateness of prediction models. Results show that capital ratios, interest income compared to interest expenses, non-interest income compared to non-interest expenses, return on equity, and provisions for loan losses have significantly negative correlations with bank failure. However, loan ratios, non-performing loans, and fixed assets all have significantly positive correlations with bank failure. In addition, the accuracy of the logistic model for banks from NAFTA countries provides the best prediction accuracy regarding bank failure.

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.

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

Depreciações de activos fixos tangíveis: o impacto da alteração dos métodos de depreciação nos resultados das entidades

Dissertação para obtenção do Grau de Mestre em Contabilidade e Finanças Orientadora: Mestre Helena Maria Santos de Oliveira

An efficient method for optimal location and sizing of fixed and switched shunt capacitors in large distribution systems

This paper proposes a computationally efficient methodology for the optimal location and sizing of static and switched shunt capacitors in large distribution systems. The problem is formulated as the maximization of the savings produced by the reduction in energy losses and the avoided costs due to investment deferral in the expansion of the network. The proposed method selects the nodes to be compensated, as well as the optimal capacitor ratings and their operational characteristics, i.e. fixed or switched. After an appropriate linearization, the optimization problem was formulated as a large-scale mixed-integer linear problem, suitable for being solved by means of a widespread commercial package. Results of the proposed optimizing method are compared with another recent methodology reported in the literature using two test cases: a 15-bus and a 33-bus distribution network. For the both cases tested, the proposed methodology delivers better solutions indicated by higher loss savings, which are achieved with lower amounts of capacitive compensation. The proposed method has also been applied for compensating to an actual large distribution network served by AES-Venezuela in the metropolitan area of Caracas. A convergence time of about 4 seconds after 22298 iterations demonstrates the ability of the proposed methodology for efficiently handling large-scale compensation problems.

Sraffa on Fixed Capital, Money and the Phases of Capitalism

Copyright © 2014 Taylor & Francis.

Immunohistochemistry in formalin-gel fixed tissues

There are several hazards in histopathology laboratories and its staff must ensure that their professional activity is set to the highest standards while complying with the best safety procedures. Formalin is one of the chemical hazards to which such professionals are routinely exposed. To decrease this contact, it is suggested that 10% neutral buffered liquid formalin (FL) is replaced by 10% formalin-gel (FG), given the later reduces the likelihood of spills and splashes, and decreased fume levels are released during its handling, proving itself less harmful. However, it is mandatory to assess the effectiveness of FG as a fixative and ensure that the subsequent complementary techniques, such as immunohistochemistry (IHC), are not compromised. Two groups of 30 samples from human placenta have been fixed with FG and FL fixatives during different periods of time (12, 24, and 48 hours) and, thereafter, processed, embedded, and sectioned. IHC for six different antibodies was performed and the results were scored (0–100) using an algorithm that took into account immunostaining intensity, percentage of staining structures, non-specific immunostaining, contrast, and morphological preservation. Parametric and non-parametric statistical tests were used (alpha = 0•05). All results were similar for both fixatives, with global score means of 95•36±6•65 for FL and 96•06±5•80 for FG, and without any statistical difference (P>0•05). The duration of the fixation had no statistical relevance also (P>0•05). So it is proved here FG could be an effective alternative to FL.

Leilão de direitos de transmissão financeiros de energia eléctrica em ambiente de mercado

Os direitos de transmissão (Transmission Rigths – TRs) correspondem, na sua essência, a contratos que conferem aos seus proprietários o direito de transmitir energia eléctrica, por um determinado caminho, a um preço fixo. Na actualidade vive-se uma era de liberalização dos mercados de energia eléctrica nos quais, no caso concreto dos mercados de TRs, os diversos agentes podem ceder os TRs que possuem a outros agentes desde que cumpram certos requisitos impostos pelo sistema na figura do seu operador de sistema (Independent System Operator – ISO). Neste sentido, o ISO oferece, aos diversos agentes do mercado, algumas ferramentas que lhes permite transaccionar, sob sua orientação, os seus respectivos TRs fazendo-se cumprir todos os requisitos indispensáveis para o efeito. A mais popular dessas ferramentas, nos principais mercados energético da actualidade, é o leilão. Com o presente trabalho de dissertação é pretendido apresentar-se um modelo para a resolução do problema inerente a um leilão de TRs em ambiente de mercado, neste caso concreto de direitos de transmissão financeiros de energia eléctrica (Financial Transmission Rigths – FTRs). Neste sentido foi desenvolvido um simulador informático (SIM_AuctFTR) que implementa um modelo para este tipo de problemas. Este trabalho foi estruturado essencialmente em três etapas com objectivos inerentes. Assim, numa primeira fase da realização deste trabalho, foi realizado um estudo de diversos conceitos e metodologias inerentes ao problema de leilão de FTRs em ambiente de mercado, suportado por uma sólida base bibliográfica. A segunda fase tratou-se do desenvolvimento do algoritmo da aplicação computacional que solucione um problema de um leilão de FTRs. O SIM_AuctFTR foi desenvolvido sobre o pressuposto da maximização dos rendimentos financeiros provenientes da atribuição dos FTRs propostos a leilão, tendo estes últimos de coabitar no sistema respeitando as restrições técnicas a que este são inerentes, mesmo na eventualidade da ocorrência de contingências de nível ‘n-1’. Por último, numa terceira fase, partindo da aplicação desenvolvida, foram realizados 4 casos de estudos com outras tantas redes eléctricas de forma a testar a robustez da ferramenta desenvolvida.

Socioeconomic inequities in the health and nutrition of children in low/middle income countries

OBJECTIVE: To describe the effects of social inequities on the health and nutrition of children in low and middle income countries. METHODS: We reviewed existing data on socioeconomic disparities within-countries relative to the use of services, nutritional status, morbidity, and mortality. A conceptual framework including five major hierarchical categories affecting inequities was adopted: socioeconomic context and position, differential exposure, differential vulnerability, differential health outcomes, and differential consequences. The search of the PubMed database since 1990 identified 244 articles related to the theme. Results were also analyzed from almost 100 recent national surveys, including Demographic Health Surveys and the UNICEF Multiple Indicator Cluster Surveys. RESULTS: Children from poor families are more likely, relative to those from better-off families, to be exposed to pathogenic agents; once they are exposed, they are more likely to become ill because of their lower resistance and lower coverage with preventive interventions. Once they become ill, they are less likely to have access to health services and the quality of these services is likely to be lower, with less access to life-saving treatments. As a consequence, children from poor family have higher mortality rates and are more likely to be undernourished. CONCLUSIONS: Except for child obesity and inadequate breastfeeding practices, all the other adverse conditions analyzed were more prevalent in children from less well-off families. Careful documentation of the multiple levels of determination of socioeconomic inequities in child health is essential for understanding the nature of this problem and for establishing interventions that can reduce these differences.

Beyond the income inequality hypothesis and human health: a worldwide exploration

OBJECTIVE: To analyze whether the relationship between income inequality and human health is mediated through social capital, and whether political regime determines differences in income inequality and social capital among countries. METHODS: Path analysis of cross sectional ecological data from 110 countries. Life expectancy at birth was the outcome variable, and income inequality (measured by the Gini coefficient), social capital (measured by the Corruption Perceptions Index or generalized trust), and political regime (measured by the Index of Freedom) were the predictor variables. Corruption Perceptions Index (an indirect indicator of social capital) was used to include more developing countries in the analysis. The correlation between Gini coefficient and predictor variables was calculated using Spearman's coefficients. The path analysis was designed to assess the effect of income inequality, social capital proxies and political regime on life expectancy. RESULTS: The path coefficients suggest that income inequality has a greater direct effect on life expectancy at birth than through social capital. Political regime acts on life expectancy at birth through income inequality. CONCLUSIONS: Income inequality and social capital have direct effects on life expectancy at birth. The "class/welfare regime model" can be useful for understanding social and health inequalities between countries, whereas the "income inequality hypothesis" which is only a partial approach is especially useful for analyzing differences within countries.

How many low birthweight babies in low- and middle-income countries are preterm?

OBJECTIVE: To assess the prevalence of preterm birth among low birthweight babies in low and middle-income countries. METHODS: Major databases (PubMed, LILACS, Google Scholar) were searched for studies on the prevalence of term and preterm LBW babies with field work carried out after 1990 in low- and middle-income countries. Regression methods were used to model this proportion according to LBW prevalence levels. RESULTS: According to 47 studies from 27 low- and middle-income countries, approximately half of all LBW babies are preterm rather than one in three as assumed in studies previous to the 1990s. CONCLUSIONS: The estimate of a substantially higher number of LBW preterm babies has important policy implications in view of special health care needs of these infants. As for earlier projections, our findings are limited by the relative lack of population-based studies.

Imparidade de ativos fixos tangíveis: aspetos contabilísticos, fiscais e de auditoria

Dissertação apresentada ao Instituto Superior de Contabilidade e Administração do Porto para a obtenção do grau de Mestre em Auditoria Orientada por: Mestre Carlos Martins