The taxation of international maritime leasing profits : has the commissioners ship come in?

In light of McDermott Industries (AUST) Pty Ltd v Commissioner of Taxation, and Draft Taxation Ruling TR 2006/D8, this article considers the current Australian taxation position of profits arising from the cross-border leasing of vessels in the maritime industry. It focuses on the tax treaties to which Australia is a party, in particular the application of the business profits provisions of those treaties, and the deemed existence of a permanent establishment where substantial equipment, owned by a fiscal non-resident, is used within Australian waters.

Solanum americanum as a reservoir of natural enemies of the tomato red spider mite, Tetranychus evansi (Acari: Tetranychidae)

Brazilian populations of the pathogenic fungus Neozygites floridana (Weiser & Muma) Remaudiere & S. Keller (Entomophthoromycotina: Entomophthorales) and the predatory mite Phytoseiulus longipes Evans (Acari: Phytoseiidae) are potential candidates for introduction into Africa for classical biological control of the tomato red spider mite, Tetranychus evansi Baker & Pritchard (Acari: Tetranychidae). The efficiency of these natural enemies against T. evansi has been demonstrated under laboratory conditions, but little is known about their performance on native Solanaceae in the field. The American nightshade, Solanum americanum Mill., is native to the Americas and may serve as an alternative host plant for T. evansi and its natural enemies in the absence of tomato plants. In this work, we studied the population dynamics of T. evansi and its natural enemies on S. americanum in a screen house, semi-field and field plots in Recife, Pernambuco, Brazil, to evaluate the potential of natural enemies for controlling T. evansi. Of the four natural enemies found in association with T. evansi, only N. floridana and P. longipes were clearly associated with the reduction of the populations of T. evansi. Neozygites floridana was observed in a screen house, semi-field and field plots, but P. longipes was only detected in the semi-field plots. Increases in the population of T. evansi were always followed by increases in the density of one of these natural enemies, suggesting that they were important factors regulating T. evansi populations on S. americanum. The presence of this host plant near the release sites in Africa thus might increase the chances for the permanent establishment of these natural enemies.

Imposte indirette sul commercio elettronico

In questo lavoro si analizza l’imposizione indiretta nel commercio elettronico; l’analisi si è basata sullo studio della normativa Comunitaria (Direttive Europee ) e la legislazione e Italiana, esponendo anche le differenze con il profilo legislativo brasiliano (softwares e libri).Esposti i contributi delle istituzione internazionali (conferenze ed/o proposte della Unione Europea) per l’inquadramento tipologico e fiscale del commercio elettronico, sono stati analizzati i profili generali dell’istituto della stabile organizzazione ai fini dell’imposizione dell’IVA e al commercio elettronico, distinguendo anche tra le transazioni elettroniche considerabili come cessione di beni e quelle considerabili prestazioni di servizi, in base alla materialità o alla dematerializzazione del bene scambiato. Anche il principio di territorialità nelle prestazioni di servizi è stato analizzato tramite analisi dei regimi ordinario e speciale riguardanti gli operatori extracomunitari.

Carbon cycle change in the Eocene

The transition from the extreme global warmth of the early Eocene 'greenhouse' climate ~55 million years ago to the present glaciated state is one of the most prominent changes in Earth's climatic evolution. It is widely accepted that large ice sheets first appeared on Antarctica ~34 million years ago, coincident with decreasing atmospheric carbon dioxide concentrations and a deepening of the calcite compensation depth in the world's oceans, and that glaciation in the Northern Hemisphere began much later, between 10 and 6 million years ago. Here we present records of sediment and foraminiferal geochemistry covering the greenhouse-icehouse climate transition. We report evidence for synchronous deepening and subsequent oscillations in the calcite compensation depth in the tropical Pacific and South Atlantic oceans from ~42 million years ago, with a permanent deepening 34 million years ago. The most prominent variations in the calcite compensation depth coincide with changes in seawater oxygen isotope ratios of up to 1.5 per mil, suggesting a lowering of global sea level through significant storage of ice in both hemispheres by at least 100 to 125 metres. Variations in benthic carbon isotope ratios of up to ~1.4 per mil occurred at the same time, indicating large changes in carbon cycling. We suggest that the greenhouse-icehouse transition was closely coupled to the evolution of atmospheric carbon dioxide, and that negative carbon cycle feedbacks may have prevented the permanent establishment of large ice sheets earlier than 34 million years ago.

Middle to late Miocene oxygen isotope stratigraphy of ODP site 1085 (SE Atlantic): new constrains on Miocene climate variability and sea-level fluctuations

The middle Miocene delta18O increase represents a fundamental change in earth's climate system due to a major expansion and permanent establishment of the East Antarctic Ice Sheet accompanied by some effect of deepwater cooling. The long-term cooling trend in the middle to late Miocene was superimposed by several punctuated periods of glaciations (Mi-Events) characterized by oxygen isotopic shifts that have been related to the waxing and waning of the Antarctic ice-sheet and bottom water cooling. Here, we present a high-resolution benthic stable oxygen isotope record from ODP Site 1085 located at the southwestern African continental margin that provides a detailed chronology for the middle to late Miocene (13.9-7.3 Ma) climate transition in the eastern South Atlantic. A composite Fe intensity record obtained by XRF core scanning ODP Sites 1085 and 1087 was used to construct an astronomically calibrated chronology based on orbital tuning. The oxygen isotope data exhibit four distinct delta18O excursions, which have astronomical ages of 13.8, 13.2, 11.7, and 10.4 Ma and correspond to the Mi3, Mi4, Mi5, and Mi6 events. A global climate record was extracted from the oxygen isotopic composition. Both long- and short-term variabilities in the climate record are discussed in terms of sea-level and deep-water temperature changes. The oxygen isotope data support a causal link between sequence boundaries traced from the shelf and glacioeustatic changes due to ice-sheet growth. Spectral analysis of the benthic delta18O record shows strong power in the 400-kyr and 100-kyr bands documenting a paleoceanographic response to eccentricity-modulated variations in precession. A spectral peak around 180-kyr might be related to the asymmetry of the obliquity cycle indicating that the response of the dominantly unipolar Antarctic ice-sheet to obliquityinduced variations probably controlled the middle to late Miocene climate system. Maxima in the delta18O record, interpreted as glacial periods, correspond to minima in 100-kyr eccentricity cycle and minima in the 174-kyr obliquity modulation. Strong middle to late Miocene glacial events are associated with 400-kyr eccentricity minima and obliquity modulation minima. Thus, fluctuations in the amplitude of obliquity and eccentricity seem to be the driving force for the middle to late Miocene climate variability.

Dos prejuízos no regime de participation exemption: a relação entre estabelecimento estável e filial

Mestrado em Fiscalidade

Comércio electrónico - O tratamento contabilístico e fiscal das transacções via comércio electrómico

Mestrado em Contabilidade Internacional

Letter from Jacques Judah Lyons to trustees of K. K. S. I. regarding establishment of permanent minyan

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Documents présentés au comité et relatifs a des projets déjà existants pour l'établissement d'une Cour permanente de justice internationale ... Documents presented to the committee relating to existing plans for the establishment of a permanent court of international justice.

Mode of access: Internet.

Plan for repatriation of the dead of World War II and establishment of permanent United States military cemeteries at home and abroad

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Biogeographic analysis of the Tortugas Ecological Reserve: Examining the refuge effect following reserve establishment

Almost 120 days at sea aboard three NOAA research vessels and one fishing vessel over the past three years have supported biogeographic characterization of Tortugas Ecological Reserve (TER). This work initiated measurement of post-implementation effects of TER as a refuge for exploited species. In Tortugas South, seafloor transect surveys were conducted using divers, towed operated vehicles (TOV), remotely operated vehicles (ROV), various sonar platforms, and the Deepworker manned submersible. ARGOS drifter releases, satellite imagery, ichthyoplankton surveys, sea surface temperature, and diver census were combined to elucidate potential dispersal of fish spawning in this environment. Surveys are being compiled into a GIS to allow resource managers to gauge benthic resource status and distribution. Drifter studies have determined that within the ~ 30 days of larval life stage for fishes spawning at Tortugas South, larvae could reach as far downstream as Tampa Bay on the west Florida coast and Cape Canaveral on the east coast. Together with actual fish surveys and water mass delineation, this work demonstrates that the refuge status of this area endows it with tremendous downstream spillover and larval export potential for Florida reef habitats and promotes the maintenance of their fish communities. In Tortugas North, 30 randomly selected, permanent stations were established. Five stations were assigned to each of the following six areas: within Dry Tortugas National Park, falling north of the prevailing currents (Park North); within Dry Tortugas National Park, falling south of the prevailing currents (Park South); within the Ecological Reserve falling north of the prevailing currents (Reserve North); within the Ecological Reserve falling south of the prevailing currents (Reserve South); within areas immediately adjacent to these two strata, falling north of the prevailing currents (Out North); and within areas immediately adjacent to these two strata, falling south of the prevailing currents (Out South). Intensive characterization of these sites was conducted using multiple sonar techniques, TOV, ROV, diver-based digital video collection, diver-based fish census, towed fish capture, sediment particle-size, benthic chlorophyll analyses, and stable isotope analyses of primary producers, fish, and, shellfish. In order to complement and extend information from studies focused on the coral reef, we have targeted the ecotone between the reef and adjacent, non-reef habitats as these areas are well-known in ecology for indicating changes in trophic relationships at the ecosystem scale. Such trophic changes are hypothesized to occur as top-down control of the system grows with protection of piscivorous fishes. Preliminary isotope data, in conjunction with our prior results from the west Florida shelf, suggest that the shallow water benthic habitats surrounding the coral reefs of TER will prove to be the source of a significant amount of the primary production ultimately fueling fish production throughout TER and downstream throughout the range of larval fish dispersal. Therefore, the status and influence of the previously neglected, non-reef habitat within the refuge (comprising ~70% of TER) appears to be intimately tied to the health of the coral reef community proper. These data, collected in a biogeographic context, employing an integrated Before-After Control Impact design at multiple spatial scales, leave us poised to document and quantify the postimplementation effects of TER. Combined with the work at Tortugas South, this project represents a multi-disciplinary effort of sometimes disparate disciplines (fishery oceanography, benthic ecology, food web analysis, remote sensing/geography/landscape ecology, and resource management) and approaches (physical, biological, ecological). We expect the continuation of this effort to yield critical information for the management of TER and the evaluation of protected areas as a refuge for exploited species. (PDF contains 32 pages.)

Comparison of permanent and temporary streams of calcareous Provence [Translation from: Annales de Limnologie 9(3) 273-292, 1973]

The rainfall regime and the karstic nature of the subsoil determines the alternation of a period of flow and a period of drought for a large number of Mediterranean streams. Amongst this type of stream it is possible to distinguish temporary streams, characterised by a period of flow for several months permitting the establishment of the principal groups of aquatic insects; and ephemeral streams whose very brief period of flow permits the establishment of a community reduced to a few species of Diptera. This paper aims to study the structure of the communities which colonise this particular type of stream and the ecology of the principal species which constitute these communities. Four French temporary streams were examined and temperature regimes, dissolved oxygen, calcium and magnesium measured. Samples of fauna were taken regularly and the biotic composition established. The analysis of similarities between the three permanent streams are discussed and compared with permanent streams.

Arrest of root formation in a permanent maxillary central incisor subsequent to trauma and pulp necrosis to the primary predecessor

This paper reports a case in which a previous traumatic injury at the age of 2 and pulp necrosis to a primary incisor resulted in a rare injury to the permanent successor tooth. The radiographic examination at the age of 9 showed the arrest of root formation of the permanent maxillary right central incisor, which did not erupt. Tooth 11 was extracted and a functional removable space maintainer was prepared. At the age of 17, the patient received an anterior fixed prosthesis for re-establishment of the esthetics, phonetics and deglutition.

Field experiments on the dispersal, establishment and colonization of lichens on a slate rock surface

A sample of run-off water from a vertical, slate rock surface in Wales, U.K. contained abundant fragments of the lichen Parmelia glabratula ssp. fuliginosa from about 0.6 to 8.0 mm in diameter, a few fragments of Parmelia conspersa from 0.6 to 4.0 mm in diameter and a large number of unidentified propagules from 0.2 to 0.5 mm in diameter. The colonization of permanent plots on the rock surface was studied over six years. At the end of the experiment relatively few thalli of Parmelia conspersa, Parmelia glabratula ssp. fuliginosa and Buellia aethalea had established in plots on undisturbed and newly-exposed slate. Fragments (2 mm in diameter) of Parmelia conspersa placed on horizontal pieces of slate survived up to 120 days in cracks, 20 days on a thin smear of bird droppings but only 2-3 days on smooth slate, against small joints in the rock or in small holes. Isidia of Parmelia conspersa placed on horizontal pieces of slate established equally in plots on smooth undisturbed slate and in plots on the surface exposed after the removal of large Parmelia conspersa thalli, but less well on newly-exposed slate. These results suggest that lichen propagules are abundant in run-off water but establishment is a hazardous process. This may be attributable to a shortage of suitable sites on the substratum for attachment of propagules.