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1
Mangoyi, Ngonidzashe. "Are expenses and losses incurred as a result of embezzlement tax-deductable?" Diss., University of Pretoria, 2015. http://hdl.handle.net/2263/53153.
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The study analyses whether taxpayers may deduct for tax purposes losses and expenses which they incur as a result of embezzlement activities. Whilst the SCA finally got the chance and held that income which is illegally obtained by a taxpayer as a result of illegal activities indeed forms part of the taxpayer s gross income, the SCA is still to get the chance to pronounce whether taxpayers should be allowed to deduct expenses and losses which are incurred as a result of embezzlement activities which may be perpetrated by shareholders, partners, senior managers, junior employees and people unrelated to the taxpayers.
The study utilises legislation, cases and commentary from South Africa and other jurisdictions. For a deduction to be allowed for losses and expenditure which are incurred as a result of embezzlement, it must be established that losses and expenditure which the taxpayer incurs as a result of embezzlement are sufficiently close to the taxpayer s production of income as held by the court in CoT v Rendle.1 As required by section 11(a) of the Act, embezzlement losses and expenditure which are incurred in the production of income may be allowed for deduction. For a deduction to be allowed, the risk of incurring the loss or the expenditure must be inherent to the business enterprise of the taxpayer.
The study concludes by proffering recommendations which our courts can consider when they get an opportunity to pronounce on whether losses and expenditure which taxpayers incur as a result of embezzlement activities come before our courts again.
The study recommends that losses and expenditure which are incurred by taxpayers as a result of embezzlement activities by partners and shareholders in a firm should not be allowed for deduction, and that they should rather be treated as drawings by those partners or shareholders.
The study recommends that losses and expenditure which are incurred as a result of embezzlement activities by senior managers in a firm may be allowed if the senior managers did not occupy a position which is akin to that of a shareholder of the company. The study recommends, in line with the decision in Rendle2 that losses and expenditure which are incurred as a result of embezzlement activities by people unrelated to the company should be allowed for deduction. The study also recommends that losses and expenses incurred as a result of embezzlement by junior employees should be allowed for deduction.
Finally, the study recommends that as embezzlement activities are secretive and may take long to be detected, the Act must be interpreted flexibly so that taxpayers are not restricted to claiming embezzlement losses and expenditure in the years in which the embezzlement activities occur, as taxpayers may be disadvantaged if they discover embezzlement after some period. Taxpayers should be allowed to claim for tax deductions in the year which they discover the embezzlement losses, even though the losses might have been incurred in prior years. This is the approach which was advanced in the United States cases in Alison v United States3 and United States v Stevenson-Chislett Inc4 and also the approach which is used by the United States Treasury.Mini Dissertation (LLM)--University of Pretoria, 2015.
Mercantile Law
LLM
Unrestricted
2
Pettersson, Johan, and Edmund Wu. "Do tax evaders manage earnings more? : A quantitative study on the relationship between tax evasion and earnings management." Thesis, Uppsala universitet, Företagsekonomiska institutionen, 2015. http://urn.kb.se/resolve?urn=urn:nbn:se:uu:diva-255889.
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The relationship between earnings management and tax manipulation has been discussed in academia recently. We contribute to this discussion by using a list of tax evader companies, to test the relationship. The list was supplied by the Swedish Tax Agency and consists of public companies from the Swedish stock exchanges. Our findings show that tax evader companies are more prone to manage their earnings and that they do it by reporting small earnings. The effect of labelling the companies as tax manipulators does also not change the extent that they manipulate their earnings in the future. There is therefore no disciplinary effect from the tax evader fine on a manipulating company to behave more credible in the future. Out of our results the most unexpected was however that when we compare the NASDAQ companies with the ones listed on less liquid stock exchanges the NASDAQ ones were more pervasive in managing their earnings. This goes against our own hypothesis as well as previous literature and shows that investors have to be careful also when investing in premium markets.
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Pillay, Neermala Neelavathy. "Assessed losses: the trade and income from trade requirements as set out in section 20 of the Income Tax Act of 1962." Thesis, Nelson Mandela Metropolitan University, 2012. http://hdl.handle.net/10948/1670.
Full textAbstract:
Section 20 of the Income Tax Act, No 58 of 1962 allows a taxpayer that incurs an assessed loss to carry forward the balance of assessed loss incurred, to be set off against taxable income earned in or added to losses incurred in future years. The issues regarding the carry forward of assessed losses in terms of section 20 is complex and in terms of the said section, a company is only entitled to set off its assessed loss from the previous year against its taxable income in the current year, if the taxpayer has carried on a trade during the current year and has derived income from that trade. Under the provisions of section 20(2A), a taxpayer other than a company can utilise an assessed loss even if no trading has been conducted. Assessed losses of natural persons, may however be ring-fenced. The aim of this treatise was twofold. Firstly it was to gain clarity on the „trade‟ and „income from trade‟ issues and secondly to compare South African legislation with that of Australia, with a view to recommending a change in our rules regarding the treatment of assessed losses in the context of companies. The critical lessons to be learned from the cases presented, is that liquidators, creditors and others must ensure that the company continues trading in order to x keep the assessed losses valid. Realisation of assets (including stock), and the collection of outstanding debts during liquidation does not constitute the carrying on of a trade in terms of s 20(1). The continuity of trade is an important element in regard to the carry forward of assessed losses to be utilised in the current and future years. Therefore it is important that a company carries on some activity that falls within the definition of trade. In the landmark case of SA Bazaars, it was held that a company did not have to trade continuously throughout the year to qualify for the set-off of the assessed loss or carry forward of the assessed loss, that is, to trade for say part of the year. The court however left open the issue of whether it was necessary to derive income from that trade. In order to clarify the issues regarding assessed losses, SARS issued Interpretation Note 33 granting taxpayers a concession in certain cases where a company has traded, but not derived income from that trade. But in ITC 1830, the court ruled that a company must trade and must derive income from that trade in order to carry forward its assessed loss, which effectively means that SARS cannot apply Interpretation Note 33. SARS does not have the authority to make concession which is contrary to the wording of the Act. xi In Australia, operating losses can be carried forward indefinitely to be set-off against future income, provided a company meets the more than 50% continuity of ownership test. Where the continuity test fails, losses can be deducted if the same business is carried on in the income year (the same business test). From the research conducted and in order to solve the issues surrounding the carry forward of assessed losses it was suggested that one of the following be adopted :- The method used in Australia for the carry forward of assessed losses., or A decision of the Supreme Court of Appeal is needed for a departure from the literal meaning of the words pertaining to the requirements regarding the carry forward of assessed losses. Furthermore, to clarify the definition of „income‟, as used in the context of s20, is it gross income less exempt income or taxable income?. If section 20 relates to taxable income, then an assessed loss will never be increased, which it is submitted, is not what the legislature intended. Section 20 ought to be revisited to eliminate any uncertainty about the income requirement and in the context in which the word „income‟ is used in that section.
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Nkumanda, Nomhle Carol. "The intended or unintended income tax consequences arising from losses on loans : a case study analysis." Master's thesis, University of Cape Town, 2011. http://hdl.handle.net/11427/13045.
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Includes bibliographical references.This research will introduce the concept of debt forgiveness and highlight vanous definitions and legal concepts such as prescription, compromise, and other forms of debt relinquishments.
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Coetzee, Izak Jacobus. "A critical analysis as to whether a company is entitled to carry forward assessed losses if such company has traded but has derived no income therefrom." Master's thesis, Faculty of Commerce, 2021. http://hdl.handle.net/11427/33688.
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The Income Tax Act No 58 of 1962 provides for tax to be levied on an annual basis (i.e. income and expenditure are generally calculated and determined in respect of a single year of assessment). Section 20(1) makes provision for the possibility that the allowable deductions may exceed a taxpayer's income by allowing for the carrying forward of any balance of assessed loss to subsequent years of assessment. It therefore provides for taxpayers to utilise assessed losses determined in previous tax periods against the income derived in future tax periods. Our courts have decided that a company which does not trade during a specific year of assessment forfeits its right to carry forward its balance of assessed loss from the preceding year of assessment. What has been left undecided in our superior courts however (although has been considered in our Tax Courts), is whether a company would also forfeit its right to carry forward its balance of assessed loss in the event where such a company carried on a trade during the current year of assessment, but derived no income therefrom. The primary research question in this study is whether a company would be allowed to carry forward its balance of assessed loss determined at the end of its previous year of assessment to its current year of assessment, in circumstances where it derived no ‘income' from its trading activities during the current year of assessment. This study also considers, as a secondary research question, whether the recent proposals made by Treasury in terms of the Budget Speech held on 26 February 2020, would have an impact on the primary research question. In order to address the primary and secondary research questions, this study considers the wording of section 20 in the light of the guidance on interpreting fiscal statutes as provided by our courts. The study also considers the views expressed in our courts in relation to section 20(1) as well as the relevant commentary on these views. Furthermore, the study considers SARS' view on section 20 as well as whether the recent proposals made by Treasury have an impact on the carrying forward of a company's balance of assessed loss. It is concluded that in terms of the recent proposal made by Treasury, a company whose trading activities result in a loss should be unaffected by the proposed amendments, although this can only be confirmed once the proposed legislation in this regard has been made available. It is further concluded that a superior court has not yet interpreted section 20(1) in terms of the current approach to the interpretation of statutes, and it is submitted that a superior court may come to the conclusion that a company would be allowed to carry forward its balance of assessed loss determined at the end of its previous year of assessment to its current year of assessment, even though it had derived no income from its trading activities during its current year of assessment.
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Mehrmann, Annika, and Caren Sureth-Sloane. "Tax Loss Offset Restrictions and Biased Perception of Risky Investments." WU Vienna University of Economics and Business, Universität Wien, 2017. http://epub.wu.ac.at/5798/1/SSRN%2Did3046543.pdf.
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We investigate how tax loss offset restrictions affect an investor's evaluation of risky investments
under bounded rationality. We analytically identify behavioral tax effects for different levels
of loss offset restrictions, tax rate and prospect theoretical biases (loss aversion, probability
weighting and reference dependence) and find tax loss offset restrictions significantly bias investor
perception, even more heavily than the tax rate. If loss offset restrictions are rather generous, investors
are very loss averse or assign a huge weight to loss probabilities, taxation is likely to increase the
preference value of risky investments (behavioral tax paradox). Surprisingly, the identified significant
perception biases of tax loss offset restrictions occur under both high and low tax rates and thus are
relatively insensitive to tax rate changes. Finally, we identify huge differences in behavioral tax effects
across countries indicating that tax loss offset restrictions crucially determine the perceived tax
quality of a country for risky investments. Our analysis is relevant for policy makers discussing future
tax reforms as well as for investors assessing risky investment opportunities.Series: WU International Taxation Research Paper Series
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Wiese, Peter. "An analysis of the income tax treatment of realised gains and losses from the use of short positions in South African hedge fund portfolio fundamental paired trades." Master's thesis, University of Cape Town, 2017. http://hdl.handle.net/11427/25658.
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This dissertation analyses the nature (capital or revenue) of the proceeds arising from the use of short positions in South African hedge fund fundamental paired trades. Hedge funds, which typically avail themselves of an array of alternative investment strategies such as short selling in addition to the traditional asset classes, were recently brought into the South African investment regulatory net. This was achieved by classifying regulated hedge funds as a separate category of collective investment scheme in terms of the CISCA. This categorisation brought regulated hedge funds into the ambit of section 25BA of the Income Tax Act which carries an important distinction between amounts of a capital nature and amounts of a revenue nature. Given that hedge funds may use short positions for both profit-seeking and risk-mitigation purposes, the resulting proceeds from short sales could be capital or revenue in nature from a tax perspective based on the surrounding facts of the trade. The onus of discharging the proof that the proceeds resulting from a short sale are capital in nature is significant. The South African case law emphasises the importance of applying the various principles to the specific facts of the case. The importance of the dominant intention of the trade is highlighted, given the potentially competing purposes of profit-seeking and risk-mitigation present. Factors that should be analysed in such a scenario include the overall portfolio positioning, the size of the long and short positions relative to each other, the degree of specificity of the risk that the short position purports to hedge against, the manner of re-investment of the short sale proceeds, the level of trading activity in the hedge fund, the level of short positions in the hedge fund, the absolute sizes of the long and short positions in the context of the overall portfolio, the exposure of the hedge fund to the long position after the close out of the short position, the manner of close out of the short position and the holding period of the short position. While the analysis reveals factors that may be indicative of capital treatment, the classification of short sale proceeds as capital or revenue in nature remains a challenging task to undertake due to the potentially wide variety of facts and circumstances and the potential for undesirable consequences should an incorrect classification be made. Consequently, improved clarity through the provision of de jure guidance as to the nature of short sale proceeds would be welcome.
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Booyse, Mariska. "The utilisation of assessed losses by mining companies : critical analysis of the armgold/harmony freegold judgment." Diss., University of Pretoria, 2013. http://hdl.handle.net/2263/41253.
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The method of taking into account assessed losses in calculating the taxable income of
mining companies is of significant importance following the Armgold/Harmony Freegold
case. In this case, the court had to determine the method of calculating a mining
company’s taxable income where at least one of its mines incurred a loss and where nonmining
income was also derived. What constitutes an assessed loss, and the order in
which it should be applied in calculating a mining company’s taxable income, was central
to this case. In this study, the different approaches adopted by the parties to the case in
order to determine whether there is an assessed loss, and the order in which it should be
utilised in calculating taxable income, was analysed and compared to an analysis of the
provisions of the Income Tax Act. In terms of this comparison, the judgment was found to
be in accordance with the current legislation in the Income Tax Act. There is, however, a
lack of updated guidance on matters relating to mining tax as is evident from the different
interpretations of the provisions of the Income Tax Act by the parties to the case. Further
research is therefore recommended in order to provide updated guidance to mining
companies.Dissertation (MCom)--University of Pretoria, 2013.
am2014
Taxation
unrestricted
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Ndiko, Amina. "The regulation of foreign direct investment in Tanzania: a focus on tax incentives schemes." University of Western Cape, 2013. http://hdl.handle.net/11394/3913.
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Mota, Maroe Martin. "The meaning of "actually incurred" in section 11 of the Income Tac Act in the context of three specific transactions." Diss., University of Pretoria, 2012. http://hdl.handle.net/2263/41509.
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The Income Tax Act 58 of 1962 (“Act”) entitles taxpayers to deduct certain losses
and expenses incurred by them from their taxable income if such losses and
expenses comply with the requirements of section 11(a) of the Act. One of the
requirements of section 11(a) is that, in order to be eligible for a deduction, the
losses and expenses must have been “actually incurred” by the taxpayer.
The area of tax deductions in our tax law represents the frontline in the continuous
and inevitable war between the taxpayer (almost always desperately trying to
maximise her deductions) and the revenue authorities (as often times desperately
trying to minimise the deductions to which the taxpayer is entitled). The stage on
which the various battles which make up this mighty war between citizen and state
are fought is the court and the arsenal with which each party comes armed is the Act
and, more specifically, the absolute belief of each party in the correctness of their
interpretation of the Act, which, each party hopes, will be ably demonstrated by their
able (and often extremely expensive) counsel. Such is the determination of the
taxpayer and the tax authorities alike that the body of case law relating to this
specific area of our law is, especially when one considers that it essentially involves
on only one section of the Act, relatively voluminous.
The author’s intention is to consider only one of the requirements with which the
taxpayer must comply in order to be eligible for a deduction, namely, the requirement
that the relevant loss or expenditure must have been “actually incurred” by the
taxpayer. Despite the fact that the meaning of the phrase “actually incurred” has
been considered extensively by our courts, significant uncertainty still exists as to its
exact meaning. The author will deal with three specific contexts in which the
meaning of this phrase remains a subject of uncertainty, namely, share-based
payments, contingent liabilities and losses and expenses incurred in relation to illegal
receipts. The author will begin first by dealing with the interpretation of tax statutes, the author
will then, in general terms, consider the general deduction formula after which the
author will delve into the meaning of the phrase “actually incurred” in the contexts of
each of the transactions mentioned above.Dissertation (LLM)--University of Pretoria, 2012.
gm2014
Mercantile Law
unrestricted
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Batchelder, Walter Irving. "A study of the link-chain LIFO controversy." Diss., Virginia Polytechnic Institute and State University, 1988. http://hdl.handle.net/10919/53909.
Full textAbstract:
The accounting literature contains no evidence on the reliability of the link-chain variant of dollar-value LIFO as a method of inventory accounting as compared to the double-extension variant. The research produced the first evidence on the topic.
Process analyses of the two methods found both to be flawed, with the link-chain method seriously flawed. The link-chain method inappropriately incorporates the price-levels of periods when there is no annual layer to be restated. The resulting, and all subsequent, inventory valuations are misstated. The link-chain and double-extension methods can both produce misstated valuations in periods with layer erosion. The study identifies procedures to correct these errors.
Two quantitative experiments were conducted to evaluate the relationship of the inventory valuations produced by the two methods. The first experiment used a small amount real data; the second experiment used a large amount of synthesized data. The experimental results indicated the relationship of the valuations to be circumstantial. Based on the process analyses and the quantitative experiments, the link-chain LIFO method was determined to be an unreliable method of inventory accounting.
The quantitative experiments were also used to investigate related issues. The first experiment concluded that a dollar-value LIFO method based on Fisher’s "ideal" index methodology was practicable. The second experiment concluded that adopting the method used by the Bureau of Labor Statistics to assign base-date costs to new or changed items that enter the CPI market basket of goods and services to the double-extension LIFO method was practicable and would not diminish tax revenues. The study recommended that consideration be given to replacing the current double-extension and link-chain methods with a double-extension LIFO with the BLS method.
The second experiment also concluded that the IRS’s inventory "turnover" test is probably based on the IRS’s perception of what constitutes taxpayer practicality. The definition of practicality, however, is questioned and alternative definitions are suggested.
The study indicated that further research on the relationship of inventory valuations to the income taxation process is needed.Ph. D.
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Fourie, Susanna Janine. "The treatment of section 24J instruments denominated in a foreign currency with regard to the categorisation as fixed or variable rate instruments and the interaction between section 24J, section 25D (foreign currency translation rules) and section 24I (gains and losses on foreign exchange transactions)." Master's thesis, University of Cape Town, 2014. http://hdl.handle.net/11427/18626.
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Section 24J is regarded to be one of the most complex provisions in the Income Tax Act No. 58 of 1962. This study specifically focuses on the income tax treatment of section 24Jinstruments denominated in a foreign currency, specifically with regards to whether such instruments are fixed or variable rate instruments for purposes of section 24J and the interaction between section 24J, section 25D (foreign currency translation rules) and section 24I (gains and losses on foreign exchange transactions).The basic concepts surrounding the incurral and accrual of interest for income tax purposes, as well as of some of the general issues faced when section 24J is practically applied are discussed. Importantly it is found that although the definition of 'instrument' includes all debt instruments, regardless of whether such instruments are interest-bearing, the application of section 24J would have no impact on the issuer or holder of an instrument that is a non-interest bearing debt instrument. Also, the section 24J definition of 'interest' is wider than the common law meaning of the same term. However, as 'interest'is defined with reference to itself, the common law meaning is still very relevant. It is confirmed that section 24J poses various interpretational uncertainties which are especially highlighted when some of the key provisions of section 24J are applied in determining the interest accrual amounts based on the yield to maturity method. Applying the rules of statutory interpretation and with the aid of hypothetical examples, itis argued that foreign exchange rates would fall within the definition of a variable rate for purposes of section 24J. However, an instrument denominated in a foreign currency would be regarded as a fixed rate instrument to the extent that the amounts payable are fixed amounts specified in the applicable foreign currency or the calculation of the amount payable in the applicable foreign currency does not involve the application of a 'variable rate' (as defined).Further is it argued that section 24J merely provides for a single accrual or incurral event during each year of assessment in relation to each instrument. Therefore, where accrual amounts be denominated in a foreign currency it should be translated at the spot rate on the last day of the year of assessment (or on the date of redemption/transfer in the instance where the instrument was transferred/redeemed during the year of assessment) for purposes of determining the sum of the accrual amounts to be included in taxable income. It is also argued that the timing of the accrual and incurral of interest amounts in terms of section 24J is applied in establishing the 'transaction date' of the interest amount owing for purposes of determining 'exchange differences' at the end of any year of assessment in terms of section 24I.
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Yevgenyeva, Anzhela. "Direct taxation and the internal market : assessing possibilities for a more balanced integration." Thesis, University of Oxford, 2013. http://ora.ox.ac.uk/objects/uuid:3b286ca9-ae8c-4be7-92d3-6c3975c4dc19.
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The role of the Court of Justice of the European Union in the process of direct tax integration in the European Union (EU) has been widely discussed in the academic literature, while another important actor, the European Commission, has attracted much less attention. The Commission’s input is commonly perceived to be limited to the right of legislative initiative. This study questions such an oversimplified interpretation and draws a more nuanced picture of EU tax harmonisation by integrating an analysis of the complex regulatory approaches adopted by the Commission for the establishment and smooth functioning of the Internal Market. It is argued that the past decade brought a notable change in the Court-dominated pattern of direct tax integration. This change is apparent first in the evolution of enforcement strategies under Articles 258 and 260 TFEU; and second, in the increased reliance upon non-binding regulatory measures. Both developments have strengthened the role of the Commission, supplying it with more possibilities for influencing national direct tax systems, despite the reluctance of Member States to agree upon legislative harmonisation. Against this background, the procedural and substantive problems associated with these instruments require closer examination. The normative scope of this research covers the key procedural problems related to the infringement procedure and non-binding regulatory measures. The empirical component explores the Commission’s enforcement and coordination practices, drawing particular attention to two case studies: the tax treatment of losses in cross-border situations and exit taxation. Following the analysis of enforcement and coordination in the field of direct taxation, the study argues the need and proposes potential solutions for (i) the developing of a more comprehensive procedural framework for the infringement procedure and non-binding regulatory acts; (ii) the strengthening of accountability mechanisms; and (iii) the enhancing of the effectiveness of their application.
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Fuksová, Barbara. "Analýza uplatnění a přenositelnosti daňových ztrát v rámci EU." Master's thesis, Vysoká škola ekonomická v Praze, 2013. http://www.nusl.cz/ntk/nusl-165380.
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This thesis analyses the treatment of tax losses in the Czech Republic in national and cross-border situations in the context of the recommendations of the European Commission and trends in treatment of losses, based on the cases of the European Court of Justice. Lack of immediate relief for losses leads to asymmetry of taxation, which is one of the causes of limitation functioning of the EU internal market. The comparison with other EU Member States based Czech Republic as a country with below-average possibilities of obtaining relief for losses. These include the 8 Member States have not yet adopted any national system of group taxation. Ways to get immediate relief for losses in domestic situations, including remains fiscally transparent entities in the group structure. Cross-border loss relief is available only if doing business in certain countries either by means of transparent entities or permanent establishments. This method of obtaining relief for losses is contrary to the interpretation of freedom of establishment, according to which there should be no discrimination on the basis of the legal form of business.
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Hoffman, Ferdinand Wessel. "Assessed losses as defined by section 20 of the Income Tax Act No. 58 of 1962 : a critical analysis of anomalies that exist under current legislation and case law together with discussions on both their possible future implications and suggestions fo." Thesis, University of Cape Town, 2014. http://hdl.handle.net/11427/9620.
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Skalická, Hana. "Harmonizace zdaňování korporací v EU." Doctoral thesis, Vysoké učení technické v Brně. Fakulta podnikatelská, 2008. http://www.nusl.cz/ntk/nusl-233705.
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After accession to the European Union, tax issues acquired and are still acquiring an entirely new character. A new legal environment is forming both in the Czech Republic and in the European Union. Until now, only indirect taxes have been harmonised, with direct taxes having remained in the domain of each member state. However, we are now feeling pressure to harmonise this area as well. Cases concerning value added tax belong to those that are now most often being resolved in front of the European Court of Justice in Luxembourg. Cases regarding direct taxes are also becoming increasingly important. Will direct taxes be harmonized to the same extent as indirect taxes have? When potential investor is considering his investment into a company, he needs to match comparable figures. Definitely, one of the most important criterions is the amount of profit after taxation followed by payout of dividends. If there are different ways of taxation of corporations in various EU Member States, then there would be no possibility to compare corporations placed in various EU Member States objectively. Therefore, the aim of this thesis is, based on the research in the whole EU regarding taxation of corporations, to suggest a method how to harmonize taxation of corporations, which now prevents companies from trading in a single EU market, and also to minimize corporation’s costs of fulfilment of tax administration requirements of each Member State. This aim has been achieved through the following partial aims: .. An analysis of taxation of corporations in each of all 27 EU Member States, .. An analysis of proposals of the European Commission regarding harmonisation of taxation of companies, .. Suggestion of own method of harmonization of taxation of corporations in the EU. In conclusion, there are emphasized the contributions of this thesis to the science, to the practice and to education.
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Olsson, Sanna. "Koncernbidragsspärren - En analys av gällande rätt ur ett företagsperspektiv." Thesis, Internationella Handelshögskolan, Högskolan i Jönköping, IHH, Rättsvetenskap, 2012. http://urn.kb.se/resolve?urn=urn:nbn:se:hj:diva-19299.
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Vad gäller reglerna om tidigare års underskott utgör koncernbidragsspärren en spärregel till den annars gällande huvudregeln att tidigare års förluster får kvittas mot framtida vinster. Koncernbidragsspärren inträder vid ägarförändringar och innebär förenklat att ett underskottsföretag är förhindrat att, under en period om fem år, kvitta kvarstående underskott mot koncernbidrag som underskottsföretaget mottar från företag som inte ingick i koncernen före ägarförändringen (nya företag). Underskott som uppkommer efter ägarförändringen får dock kvittas mot koncernbidrag från nya företag. Uppsatsen syftar till att analysera och granska reglerna om koncernbidragsspärren ur ett företagsperspektiv, vilket innebär att uppsatsen ser till reglernas bakomliggande syfte och till hur reglerna fungerar vid en praktisk tillämpning. Uppsatsen har ett särskilt fokus kring i vilken turordning koncernbidrag ska beaktas vid avräkning mot befintliga underskott när ett underskottsföretag mottar koncernbidrag både från gamla och nya företag i en koncern. I RÅ 2008 ref. 69 ställdes frågan på sin spets och Högsta Förvaltningsdomstolen befäste en ny turordningsprincip där koncernbidrag från gamla företag ska beaktas före koncernbidrag från nya företag i koncernen. Det har genom uppsatsens analys av reglerna om koncernbidragsspärren påvisats att reglerna är svåra att tillämpa och i många fall råder det osäkerhet om hur reglerna ska tolkas. Det kan konstateras att problematik kvarstår avseende frågan om i vilken turordning koncernbidrag från så kallade gamla respektive nya företag ska beaktas vid avräkning mot befintliga underskott även efter RÅ 2008 ref. 69. En rådande osäkerhet om hur reglerna ska tolkas kan inte anses tillfredsställande ur ett företagsperspektiv och en översyn av reglerna vore välkommen.According to the Swedish legislation tax losses can normally be carried forward and settled against future profits in the same company unlimited of time. However, a restriction of losses being carried forward may occur in situations where change of ownership is at hand. The restrictive rule prohibits offsetting tax losses in an acquired loss-making company against group contributions received from other group companies. The restrictive rule applies up until, and including, the end of the fifth year after the year when the restriction occurred. However, losses that occur after the change of ownership are possible to offset against group contributions from other group companies. The thesis aims to analyze and review the restrictive rule from a business perspective which means that the underlying purpose of the restrictive rule and how it works in practice is examined. The thesis has a particular focus on in what order group contributions should be considered when being offset against existing deficits when the deficit company receives group contributions from old and new companies in the corporate group. In the Swedish case law RÅ 2008 ref. 69 the Supreme Administrative Court laid down a new principle of order where group contributions from an old company should be regarded before a group contribution from a new company. Through the analysis of the restrictive rule it has been demonstrated that the rule is difficult to conform to and that there is an uncertainty regarding the interpretation of it. Through the analysis of this thesis it is established that, even after RÅ 2008 ref. 69, the complexity of problems remains concerning in what order group contributions from old respectively new companies should be considered when being offset against existing deficits. A such prescribed uncertainty regarding the interpretation of the restrictive rule cannot be considered satisfactory from a business perspective and a review of the rules would be preferable.
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Tully, Jennifer Anne. "Tax breaks in U.S. agriculture : who benefits, who loses?" Thesis, Massachusetts Institute of Technology, 1986. http://hdl.handle.net/1721.1/78065.
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Thesis (M.C.P.)--Massachusetts Institute of Technology, Dept. of Urban Studies and Planning, 1986.MICROFICHE COPY AVAILABLE IN ARCHIVES AND ROTCH
Bibliography: leaves 54-56.
by Jennifer Anne Tully.
M.C.P.
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Simões, António Jacinto Valadas. "A influência da política fiscal na competitividade da economia no âmbito dos países da União Europeia: alguns determinantes." Doctoral thesis, Universidade de Évora, 2018. http://hdl.handle.net/10174/24822.
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A capacidade de atração de Investimento Direto Estrangeiro (IDE) é um fator a considerar ao aferir a competitividade da economia de um Estado. Esta tese pretende demonstrar a existência de uma relação entre políticas fiscais e a capacidade de atrair IDE e, por essa via, pretende demonstrar que as políticas fiscais são fatores relevantes na competitividade das economias dos países objeto de estudo.
A tese é constituída por três ensaios distintos, mas inter-relacionados. No primeiro ensaio procede-se a uma revisão da literatura acerca dos diversos fatores que influenciam as decisões de IDE e conclui que algumas políticas fiscais são determinantes na captação de IDE. Os dois outros ensaios analisam o impacto de certas políticas fiscais específicas na captação de IDE. Mais concretamente, o segundo ensaio procura avaliar a existência de uma relação entre a captação de IDE e os regimes fiscais de reporte de prejuízos fiscais. O terceiro ensaio versa sobre o impacto das regras fiscais de tributação de dividendos e de subcapitalização na capacidade de atrair IDE.
O objetivo do estudo é contribuir para um melhor conhecimento da relevância, na captação de IDE, das diversas políticas fiscais de dividendos, de subcapitalização e de reporte de prejuízos, vigentes em diferentes Estados Europeus. Com tal objetivo, no segundo e no terceiro ensaios analisam-se comparativamente os regimes específicos em 7 países da Europa Ocidental.
Os ensaios chegaram a um conjunto coerente de conclusões, utilizando como metodologia de análise a fuzzy set – Qualitative Comparative Analyis (fsQCA). Mais concretamente a análise fsQCA fornece evidência empírica de que a tributação dos dividendos e os regimes fiscais de subcapitalização e de reporte de prejuízos são condições centrais para a verificação do resultado (as decisões de IDE), na medida em que essas condições integram as soluções simples e as soluções intermédias, resultantes da aplicação do modelo de análise. No âmbito da análise foram também consideradas outras variáveis, não relacionadas com a política fiscal, como condições para a verificação do resultado. A análise fsQCA revela que o Produto Interno Bruto em Paridade do Poder de Compra (GDPppp) é condição periférica para a verificação do resultado; Abstract:
The attractiveness of Foreign Direct Investment (FDI) is a factor to consider when assessing the competitiveness of a State economy.
This thesis intends to demonstrate the existence of a relationship between fiscal policies and the capacity to attract FDI and by this way the thesis intends to demonstrate fiscal policies are relevant factors in economies competitiveness of the countries under study.
The thesis consists of three distinct but interrelated essays. The first essay is about literature review on the various factors that influence FDI decisions and concludes some fiscal policies are determinant in attracting FDI. The other two papers analyse the impact of certain specific fiscal policies on FDI inflows. More specifically, the second essay tries to evaluate the existence of a link between FDI inflows and tax loss carryforwards. The third essay is about the impact of the dividend withholding tax rules and of thin capitalization tax rules on the ability to attract FDI.
The objective of the study is to contribute to a better understanding of the relevance on FDI attractiveness of the taxation policies of dividends, thin capitalization and tax losses, in force in different European States.
Looking for the objective above mentioned the second and third essays compare these specific tax regimes in force on seven Western European countries.
The studies reached a coherent set of conclusions using the fuzzy set - Qualitative Comparative Analyis (fsQCA). More specifically, the fsQCA analysis provides empirical evidence that dividend taxation and thin capitalization and loss carryover tax regimes are central conditions for outcome verification (FDI decisions), as these conditions integrate simple solutions and the intermediate solutions, resulting from the application of the model analysis. In the scope of the analysis, other variables, not related to fiscal policy, were also considered as conditions for the verification of the result. The fsQCA analysis reveals that the Gross Domestic Product in Purchasing Power Parity (GDPppp) is a peripheral condition for the verification of the result.
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Kohlhase, Saskia. "Accumulation of Tax-Loss Carryforwards: The Role of Book-Tax Non-Conformity." WU Vienna University of Economics and Business, Universität Wien, 2016. http://epub.wu.ac.at/5083/1/SSRN%2Did2794992.pdf.
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Using confidential corporate income tax return data, this paper investigates the association between book-tax non-conformity (measured as book-tax differences) and tax-loss carryforwards (TLCFs). I find that TLCFs are positively associated with temporary and permanent book-tax differences. Only firms with positive pre-tax book income and negative taxable income (double-picture firms) drive the positive association between TLCFs and temporary book-tax differences. Conversely, the positive association of TLCFs and permanent book-tax differences is present for double-picture firms and the remaining firms. The results suggest that double-picture firms, which feature high TLCFs compared to their size and to the remaining firms, use temporary book-tax differences to report a lower taxable income than pre-tax book income. Thus, this paper contributes to the understanding of the drivers of rising TLCFs. This is important, as offsetting TLCFs against future profits jeopardizes a country's tax revenue. (author's abstract)Series: WU International Taxation Research Paper Series
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Sherry, Samuel Accounting Australian School of Business UNSW. "Tax-loss selling and managerial discretion." Publisher:University of New South Wales. Accounting, 2009. http://handle.unsw.edu.au/1959.4/43727.
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This thesis examines the relationship between tax-loss selling (TLS), where investors with taxable gains sell stocks that have declined in value just before the fiscal year-end to generate offsetting tax losses, and managers?? incentives to influence stock prices, either through increased disclosure or by engaging in upwards earnings management. Firms whose stock prices represent greater potential tax losses in investors?? portfolios at year-end are predicted to increase their disclosure level in June to prevent further share price falls due to TLS, and have higher levels of accruals. Using the number of discretionary, market-sensitive news releases in the Signal G announcement database to measure disclosure frequency, this thesis finds that, for a sample of 14,713 firm-year observations drawn from all ASX firms for the years 1994 to 2007, stocks with larger negative returns have higher disclosure in June, after controlling for size, performance, risk and external financing dependence. This is particularly true of small mining and exploration companies that are more reliant on voluntary disclosure as a vehicle for lowering information asymmetry. This increased disclosure does not appear to contribute to the higher July returns earned by stocks that experienced significant TLS in June. Disclosure frequency is negatively associated with the magnitude of operating and total accruals, suggesting that earnings management is less likely for firms with higher disclosure. There is also evidence that smaller firms with poor stock price performance have higher levels of operating accruals and thus may be more likely to engage in earnings management.
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Lui, Pan. "A study of tax loss in China." online access from Digital Dissertation Consortium, 2007. http://libweb.cityu.edu.hk/cgi-bin/er/db/ddcdiss.pl?3299871.
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Anastasov, Anton G. "Tax-efficient asset management via loss harvesting." Thesis, Massachusetts Institute of Technology, 2017. http://hdl.handle.net/1721.1/112829.
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Thesis: M. Eng., Massachusetts Institute of Technology, Department of Electrical Engineering and Computer Science, 2017.This electronic version was submitted by the student author. The certified thesis is available in the Institute Archives and Special Collections.
Cataloged from student-submitted PDF version of thesis.
Includes bibliographical references (page 63).
In this thesis, we study loss-harvesting--an investment strategy that realizes capital losses immediately but defers realizing capital gains as long as possible. We begin by describing a computational framework for studying the properties of loss-harvesting empirically. The main advantage of our framework is flexibility. In particular, our framework is independent of any particular choice of a source for stock return time series. After combining the framework with the Capital Asset Pricing Model as a source for simulated stock returns data, we perform a thorough sensitivity analysis and study the performance of loss-harvesting under various conditions of the financial market. By combining the framework with historical stock return time series from the S&P 500 Index, we study the performance of loss-harvesting from a different and more practical, point of view. Through this empirical exploration, we identify three new findings about loss-harvesting: (1) introducing a transaction cost rate of 1% reduces alpha by about 50% after taxes; (2) introducing regular cash contributions reduces alpha after taxes; and (3) under specific market conditions, a simple passive buy-and-hold investment strategy outperforms loss-harvesting.
by Anton G. Anastasov.
M. Eng.
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Jeong, Yu Seon, Minh Vu Luu, Mary Hall Reno, and Ina Sarcevic. "Tau energy loss and ultrahigh energy skimming tau neutrinos." AMER PHYSICAL SOC, 2017. http://hdl.handle.net/10150/625525.
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We consider propagation of high-energy earth-skimming taus produced in interactions of astrophysical tau neutrinos. For astrophysical tau neutrinos, we take generic power-law flux, E-2 and the cosmogenic flux initiated by the protons. We calculate tau energy loss in several approaches, such as dipole models and the phenomenological approach in which parametrization of the F-2 is used. We evaluate the tau neutrino charged-current cross section using the same approaches for consistency. We find that uncertainty in the neutrino cross section and in the tau energy loss partially compensate giving very small theoretical uncertainty in the emerging tau flux for distances ranging from 2 to 100 km and for the energy range between 10(6) and 10(11) GeV, focusing on energies above 10(8) GeV. When we consider uncertainties in the neutrino cross section, inelasticity in neutrino interactions and the tau energy loss, which are not correlated, i.e. they are not all calculated in the same approach, theoretical uncertainty ranges from about 30% and 60% at 10(8) GeV to about factors of 3.3 and 3.8 at 10(11) GeV for the E-2 flux and the cosmogenic flux, respectively, for the distance of 10 km rock. The spread in predictions significantly increases for much larger distances, e.g., similar to 1, 000 km. Most of the uncertainty comes from the treatment of photonuclear interactions of the tau in transit through large distances. We also consider Monte Carlo calculation of the tau propagation and we find that the result for the emerging tau flux is in agreement with the result obtained using analytic approach. Our results are relevant to several experiments that are looking for skimming astrophysical taus, such as the Pierre Auger Observatory, HAWC and Ashra. We evaluate the aperture for the Auger and discuss briefly application to the other two experiments.
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Ortmann, Regina, and Caren Sureth. "Can the CCCTB Alleviate Tax Discrimination Against Loss-making European Multinational Groups?" WU Vienna University of Economics and Business, Universität Wien, 2014. http://epub.wu.ac.at/4168/1/SSRN%2Did2442820.pdf.
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In March 2011, the European Commission submitted a proposal for a Council Directive on an optional common consolidated corporate tax base (CCCTB). If this proposed CCCTB system comes into force, taxes calculated under the currently existing system of separate accounting might be replaced by a system of group consolidation and formulary apportionment. Then, multinational groups (MNGs) would face the decision as to whether to opt for the CCCTB system. Prior research focuses mainly on the differences in economic behaviour under both systems in general. By con-trast, we study the conditions under which one or the other tax system is preferable from the per-spective of an MNG, with a particular focus on loss-offsets. We identify four effects that determine the decision of an MNG: the tax-utilization of losses, the allocation of the tax base, the dividend and intragroup interest taxation. We find mixed results, e.g., that the CCCTB system proves ad-vantageous for increasing loss/profit streams (e.g. from start-ups or R&D projects) of the individual group entities, whereas the system of separate accounting is beneficial for decreasing profit/loss streams (e.g. caused by a decrease in return from a mature product). The results of our analysis are helpful for MNGs facing the decision as to whether to opt for the CCCTB system and can also support legislators and politicians in the EU but also in other regions in their tax reform discussions. (authors' abstract)Series: WU International Taxation Research Paper Series
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Zamcheck, Abraham Moses. "Planning for a "sudden-death" inventory loss triggered by international tax competition." Thesis, Massachusetts Institute of Technology, 2016. http://hdl.handle.net/1721.1/107505.
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Thesis: M. Eng. in Logistics, Massachusetts Institute of Technology, Supply Chain Management Program, 2016.Cataloged from PDF version of thesis.
Includes bibliographical references (pages 50-51).
This study addresses a medical device company's need to relicense its products for export after declaring a new legal manufacturer. New license applications are approved at an unknown date with increasing probability within a finite time horizon. Approval results in the instantaneous obsolescence, or "sudden-death," of inventory bound for export. As a result, the company needs to re-align its supply chain strategy to avoid stock-outs or inventory obsolescence. This thesis develops a model that aids the organization in assessing the decisions and necessary information that can help navigate the transition. Potential responses include pushing inventory out of the system before obsolescence, or ramping down production in advance of the sudden-death event. Improved estimates of alternative distribution costs, shortage costs, salvage values, and production capacities will greatly aid the organization's ability to respond to the event scenario. Changing these factors suggest different optimal inventory policies. To illustrate this relationship, a dynamic programming model is derived based on a probability distributions for likely license approval times. The resulting model allows the organization to assess optimal inventory policies derived from various system assumptions. In the thesis, different product aggregations are used to assess inventory strategies for bulk-license application submission. Patterns are identified in the analysis of simulation runs, including the time period for starting alternative inventory ramp-up as well as ramp-down speed. The intent of the study is to provide an iterative method for experimenting with assumptions within the organization in order to drive a coordinated response to the sudden-death eVent. The method is intended to be useful to other organizations planning to transition in preparation-for events occurring with increasing likelihood within finite time horizons.
by Abraham Zamcheck.
M. Eng. in Logistics
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Ortmann, Regina, and Caren Sureth-Sloane. "Can the CCCTB alleviate tax discrimination against loss-making European multinational groups?" Springer Berlin Heidelberg, 2016. http://dx.doi.org/10.1007/s11573-015-0780-6.
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In March 2011, the European Commission submitted a proposal for a Council Directive on an optional common consolidated corporate tax base (CCCTB). If this proposed CCCTB system comes into force, taxes calculated under the currently existing system of separate accounting might be replaced by a system of group consolidation and formulary apportionment. Then, multinational groups (MNGs) would face the decision as to whether to opt for the CCCTB system. Prior research focuses mainly on the differences in economic behaviour under both systems in general. By contrast, we study the conditions under which one or the other tax system is preferable from the perspective of an MNG, with a particular focus on loss-offsets. We identify four effects that determine the decision of an MNG: the
tax-utilization of losses, the allocation of the tax base, the dividend and intragroup interest taxation. We find mixed results, e.g., that the CCCTB system proves advantageous for increasing loss/profit streams (e.g. from start-ups or R&D projects) of the individual group entities, whereas the system of separate accounting is beneficial for decreasing profit/loss streams (e.g. caused by a decrease in return from a mature product). The results of our analysis are helpful for MNGs facing the decision as to whether to opt for the CCCTB system and can also support legislators and politicians in the EU but also in other regions in their tax reform discussions. (authors' abstract)
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Galdunová, Natália. "Daňové dopady přeměn obchodních společností." Master's thesis, Vysoké učení technické v Brně. Fakulta podnikatelská, 2021. http://www.nusl.cz/ntk/nusl-444230.
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The diploma thesis deals with the companies’ transformation and the main focus is on the cross-border mergers and its tax implications. The theoretical part introduces the topic of companies’ transformation with focus on cross-border mergers and describes its legal, accounting and tax implications. The practical part contains of analysis of cross-border mergers made by Czech companies from 2008 to 2020. The goal of the analysis is to find out where to Czech companies make cross-border mergers most often. Then for the selected countries the tax systems and mainly the corporate income tax is described. Afterwards, with a model example, the most convenient country for cross-border merger from the tax and corporate income tax perspective is selected.
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Rosenberg, Josh. "The Effect Of Tax Loss Harvesting On Momentum In The U.S. Stock Market: An Intra Industry Group Study." Scholarship @ Claremont, 2014. http://scholarship.claremont.edu/cmc_theses/956.
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It is well understood through previous literature that strategies, which buy past winning stocks and sell past losing stocks, can generate significant positive returns. This phenomenon is known as the momentum effect in the stock market. Furthermore, there is a common accounting practice used by portfolio managers called tax loss harvesting.Tax loss harvesting is the practice of selling a security in order to create a benefit for tax purposes. This paper attempts to build upon previous literature by explaining why the momentum effect is different at the beginning of the calendar year than in the middle and assessing whether or not tax loss harvesting may play a role. A trading strategy was created which calculates the returns of winning and losing portfolios intra industry groups, around different months of the year, in attempt to explain fluctuations in the momentum effect. Evidence in support of the hypothesis that tax loss harvesting played a role in impacting momentum strategies did not prove to be statistically significant.
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Stoškutė, Simona. "Apmokestinamojo pelno apskaičiavimo ypatumai." Master's thesis, Lithuanian Academic Libraries Network (LABT), 2014. http://vddb.library.lt/obj/LT-eLABa-0001:E.02~2010~D_20140625_184536-62493.
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Lietuva per paskutinius keletą metų prarado lyderės pozicijas Vakarų Europoje lyginant apmokestinamojo pelno apskaičiavimo taisykles ir pelno mokesčio tarifo dydį, tačiau iš pirmaujančių šalių grupės nepasitraukė, nenusileidžia ji ir Latvijai bei Estijai, kuriose yra sukurtos taip pat vienos patraukliausių investuotojams pelno mokesčio sistemų Europos Sąjungoje. Siekiant įvertinti šalies patrauklumą užsienio investuotojams reikia įvertinti apmokestinamojo pelno apskaičiavimo taisykles bei apžvelgti pelno mokesčio tarifą. Šio darbo objektas yra apmokestinamasis pelnas. Tikslas – išsiaiškinti apmokestinamojo pelno apskaičiavimą. Šiam tikslui pasiekti iškelti šie svarbiausi uždaviniai: 1) išnagrinėti pelno sampratą bei pateikti informaciją apie pelno valdymą; 2) išanalizuoti Lietuvos akcinių bendrovių apmokestinamojo pelno apskaičiavimą; 3) išnagrinėti ir palyginti Lietuvos, Latvijos ir Estijos apmokestinamojo pelno apskaičiavimo tvarką; Darbą sudaro 3 pagrindinės dalys. Pirmoje dalyje “Pelno samprata ir valdymas“ nagrinėjama pelno sąvoka, išskiriami neatitikimai tarp finansinio ir mokestinio pelno bei pateikiamos pelno valdymo galimybės pasirenkant apskaitos politikos priemones. Antroje dalyje „Apmokestinamojo pelno apskaičiavimas Lietuvoje“ analizuojama akcinių bendrovių apmokestinamojo pelno apskaičiavimo tvarka, pateikiamos neapmokestinamosios pajamos, neleidžiami ir ribojamų dydžių leidžiami atskaitymai. Nagrinėjami galimi pelno mokesčio sumažinimo būdai bei metinė pelno... [toliau žr. visą tekstą]Lithuania during several recent years has lost its leading position in Western Europe compared to calculation of taxable profit rules and income tax rate, but it is still one of leading countries, it keep up with Latvia and Estonia where also are developed one of the most attractive income tax systems in the European Union. In order to evaluate country’s attractiveness to foreign investors we need to evaluate calculation of taxable profit rules and review corporate income tax rate. The subject of this investigation is taxable profit. Purpose is to find out calculation of taxable profit rules. There are main tasks to achieve the purpose: 1) to investigate concept of profit and to give information about profit management; 2) to analyze calculation of taxable profit of Lithuanian stock companies; 3) to consider and compare Lithuanian, Latvian and Estonian calculation of taxable profit. This paper consists of three main parts. In the first part “Concept of profit and management”, is considered the profit concept, differences between taxable and accounting profit, also there is written about profit management opportunities choosing of accounting policy tools. In the second part “Calculation of taxable profit in Lithuania” is analyzed stock companies calculation of taxable profit and is introduced non-taxable income, not allowed and limited amount allowed deductions. Also there is written possibilities of reducing income tax and about profit tax declaration as well its purpose. The... [to full text]
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Čondlová, Dagmar. "Společný konsolidovaný základ daně korporací (CCCTB) v EU." Master's thesis, Vysoká škola ekonomická v Praze, 2012. http://www.nusl.cz/ntk/nusl-150310.
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The aim of my thesis is through comparative analysis find the differences between the newly proposed CCCTB directive and corporate income tax systems of France, Germany and Great Britain. The work is mainly focused on the comparison method of depreciation, access to inventory, the amount of corporate tax and transfer of tax losses. Although each system has its tax certain specifics, one would assume that the authors of the proposed directive let themselves be inspired by the strong states of the European Union. However, the final chapter of my thesis shows, that the majority of monitored items was not affected by these states.
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Xu, Zhaojin. "Selling Winners, Holding Losers: Effect on Mutual Fund Performance and Flows." Diss., Virginia Tech, 2007. http://hdl.handle.net/10919/27878.
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In this dissertation, we examine whether the disposition effect, the tendency to sell winners and hold losers, exists among U.S. equity mutual funds and how the disposition effect influences fund performance and particularly flows. We find that a significant fraction (32%) of all funds exhibit some degree of disposition behavior. These funds underperform funds that are not disposition prone by 4-6% per year.
Moreover, we find that the disposition effect has a significant impact on future fund flows. Without controlling for performance, disposition-prone funds experience 2-3% less flows each quarter than other funds. The difference in flows is probably due to poor performance of such funds. However, even after controlling for performance and other factors that potentially influence flows, funds with a high disposition effect experience 0.7-2% less flows than funds without such behavior.
Past research has found that funds with low tax overhang garner larger inflows. Though disposition-prone funds are likely to have a lower tax overhang because they sell their winners quickly, we find that fund flows to disposition-prone funds are smaller than flows to non-disposition oriented funds after controlling for tax overhang. These results suggest that performance and tax efficiency as well as tax overhang are all important to mutual fund investors.Ph. D.
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González, Osnaya Ma de Lourdes. "Tan Lejos y tan cerca/ So far and so close." Thesis, Konstfack, Textil, 2018. http://urn.kb.se/resolve?urn=urn:nbn:se:konstfack:diva-6327.
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A project around loss and absence. This work is a reflection on tradition, mourning and the importance to remember. Based on how crafts relate to society in ceremonial contexts by being a tool to communicate with others. By having a reflective relation with tradition this fiber works intend to transfer the innate poetic language of symbolic materials used in rituals around death and commemoration in Mexico into new forms through specific repetitive actions in the making. Delving into the unique physical qualities of onion skin, sugar, beeswax, corn husks and paper. Seeking to evoke an emotion by diverting our perception of ordinary materials.
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Siebenthaler, Jennifer W. "ENDOWMENTS OF HIGHER EDUCATION INSTITUTIONS AND INDIVIDUAL INCOME TAX POLICY: WEALTH EROSION FROM A LOSS IN CHARITABLE CONTRIBUTIONS." UKnowledge, 2019. https://uknowledge.uky.edu/epe_etds/68.
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The most significant tax overhaul bill in over thirty years was enacted in 2017 and expected to have wide-ranging effects. The Tax Cuts and Jobs Act includes numerous policies that directly and indirectly impact the higher education sector and the effect to endowments was not addressed in the public debate leading up to enactment. Unlike expendable gifts, a reduction in endowment contributions has a cumulative effect because a gift to an endowment can benefit all subsequent years. Each year following a contribution, investment income earned on the original gift is available for spending and benefits escalate over time in amount, assuming the value of the original gift continues to grow. The purpose of this study is to analyze precisely the direct and indirect impact of personal income tax regulations on the charitable sector. It will do so by disaggregating data to delineate clearly the differential consequences that distinguish higher education from other components of the broad charitable sector umbrella. A model is developed to predict the erosion of endowment wealth following a decrease in contributions due to tax policy using panel data from a previous ten-year period assuming the tax policy was first effective beginning in year one. The erosion of overall endowment wealth is gradual, and subsectors of higher education are predicted to experience varying rates of attrition. Regression analysis is then used on giving by source data to institutional and endowment characteristics indicative of greater reliance on contributions from individuals to the endowment; the results are suggestive but inconclusive.
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Gankin, Dimitri. "Direct tax: Cross-border group consolidation in the EU : Is the criterion of a “wholly owned subsidiary” in Swedish tax legislation regarding cross-border group deductions contrary to ECJ jurisprudence?" Thesis, Högskolan i Jönköping, Internationella Handelshögskolan, 2012. http://urn.kb.se/resolve?urn=urn:nbn:se:hj:diva-19502.
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On July 1 2010 new rules regarding cross-border group deductions came into force in Sweden. The rules are based on a series of judgements which were delivered by the Court of Justice of the European Union and subsequent rulings deriving from the Swedish Supreme Administrative Court. The new set of rules is supposed to make the Swedish group consolidation system in line with EU law in the area of cross-border group consolidations. The new rules allow a resident parent to deduct the losses stemming from its non-resident subsidiary but only if the subsidiary has exhausted all the possibilities to take those losses into account in its own state of origin and the losses cannot be utilized in the future by the subsidiary or a third party. Furthermore, the non-resident subsidiary needs to be liquidated for the parent to be able to show that the possibilities have been exhausted. However, before even considering whether the subsidiary has exhausted the losses there is one criterion that need to be fulfilled; the criterion of a wholly owned subsidiary. The criterion of a wholly owned subsidiary requires a resident parent to directly own its non-resident subsidiary without any intermediate companies and that shareholding must correspond to more than 90 percent. It is the requirement of a direct shareholding which post a concern to whether that criterion can be seen as in compliance with the case-law stemming from The Court of Justice of the European Union and the Swedish Supreme Administrative Court. After revising and analysing the case-law stemming from the Court of Justice and the Swedish Supreme Administrative Court it is the author’s belief that the criterion of a wholly owned subsidiary, due to the requirement of a direct shareholding, is not in conformity with EU law and cannot be justified by the justification grounds put forward by the Swedish government.
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Tau, Baetsane Aaron. "Bank loan pricing and profitability and their connections with Basel II and the subprime mortgage crisis / B.A. Tau." Thesis, North-West University, 2008. http://hdl.handle.net/10394/2870.
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A topical issue in financial economics is the development of appropriate stochastic dynamic models for banking items and behavior. The issue here is to fulfil the need to generalize the more traditional discrete-time models of banking activity to a Levy process setting. In this thesis, under the assumption that the loan market is imperfectly competitive, we investigate the evolution of banking items such as bank assets (cash, bonds, shares, Treasuries, reserves, loans and intangible assets), liabilities (demand deposits) and bank capital (bank equity, subordinate debt and loan loss reserves). Here we consider the influence of macroeconomic factors and profitability as well as its indicators return on assets (ROA) and return on equity (ROE).
As far as bank assets are concerned, we note that loan pricing models usually reflect the financial funding cost, risk premium to compensate for the risk of default by the borrower, a premium reflecting market power exercised by the bank and the sensitivity of the cost of capital raised to changes in loans extended. On the other hand, loan losses can be associated with an offsetting expense called the loan loss provision (LLP), which is charged against Nett profit. This offset will reduce reported income but has no impact on taxes, although when the assets are finally written off, a tax-deductible expense is created. An important factor influencing loan loss provisioning is regulation and supervision. Measures of capital adequacy are generally calculated using the book values of assets and equity. The provisioning of loans and their associated write-offs will cause a decline in these capital adequacy measures, and may precipitate increased regulation by bank authorities. Greater level of regulation generally entail additional costs for the bank. Currently, this regulation mainly takes the form of the Basel II Capital Accord that has been implemented on the worldwide basis since 2008.
It is clear that bank profitability is a major indicator of financial crises for households, companies and financial institutions. An example of this from the 2007-2008 subprime mortgage crisis (SMC) is the U.S. bank, Wachovia Corp., who reported a big loss as from the first quarter of 2007 and eventually was bought by the world's largest bank, Citigroup, on 29 September 2008. A further example from the SMC is that both the failure of the Lehman Brothers investment bank and the acquisition in September 2008 of Merrill Lynch and Bear Stearns by Bank of America and JP Morgan Chase, respectively, were preceded by a decrease in profitability and an increase in the price of loans and loan losses. The subprime mortgage crisis is characterized by contracted liquidity in the global credit markets and banking system. The level of liquidity in the banking sector affects the ability of banks to meet commitments as they become due without incurring substantial losses from liquidating less liquid assets. Liquidity, therefore, provides the defensive cash or near-cash resources to cover banks' liability. An undervaluation of real risk in the subprime market is cascading, rippling and ultimately severely adversely affecting the world economy. The downturn in the U.S. housing market, risky lending and borrowing practices, and excessive individual and corporate debt levels have caused multiple adverse effects tumbled as the US housing market slumped. Banks worldwide are hoarding cash and showing a growing reluctance to lend, driving rates that institutions charge to each other on loans to record highs. Also, global money markets are inoperative, forcing increased injections of cash from central banks. The crisis has passed through various stages, exposing pervasive weaknesses in the global financial system and regulatory framework.
The stochastic dynamics of the aforementioned banking items assist in formulating a maximization problem that involves endogenous variables such as profit consumption, the value of the bank's investment in loans and provisions for loan losses as control variants. In particular, we demonstrate that the bank is able to maximize its expected utility of discounted profit consumption over a random time interval, [t,r], and terminal profit at time r. Here the term profit consumption refers to the consumption of the bank's profits by dividend payments on equity and interest and principal payments on subordinate debt. The associated Hamilton-Jacobi-Bellman (HJB) equation has a smooth solution when the optimal controls are computed by means of power, logarithmic and exponential utility functions. This enables us to make a direct comparison between the economic properties of the solutions for different choices of the utility function.
In keeping with the main theme of this thesis, we simulate the financial indices ROE and ROA that are two measures of bank profitability. We further discuss optimization with power utility where we show the convergence of the Markov Chain Approximation Method (MCAM) and the impact of varying the model parameters in the form of loan loss severity, P, and loan loss frequency, Thesis (Ph.D. (Applied Mathematics))--North-West University, Potchefstroom Campus, 2009.
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Hoppe, David M. "Designing for loss." This title; PDF viewer required. Home page for entire collection, 2009. http://archives.udmercy.edu:8080/dspace/handle/10429/9.
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Hall, Bethane Jo Pierce. "An Analysis of the Equity and Revenue Effects of the Elimination or Reduction of Homeowner Preferences." Thesis, North Texas State University, 1987. https://digital.library.unt.edu/ark:/67531/metadc332080/.
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One perceived deficiency in the tax system is its unfairness (inequity). One area in which unfairness has been alleged is the favoritism shown toward homeowners. The focus of this study was on the effects of homeowner preferences on the Federal tax system. The overall impact of homeowner preferences can be said to produce three major results—loss of revenue, reduction in horizontal equity, and reduction in vertical equity.
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Mohamad, Housam. "The impact of international financial reporting standards on earnings quality : EU evidence." Thesis, Brunel University, 2016. http://bura.brunel.ac.uk/handle/2438/15830.
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Earnings have numerous properties that can be investigated, including earnings smoothness, abnormal accruals after modelling the accruals process and asymmetric timely loss and gain recognition. In latest decades, as earnings are the main source of firm-specific information for investors, earnings quality has become a significant focus in the financial accounting field. Moreover, high-quality financial reporting helps investors improve decisions and better evaluate firm performance because capital markets depend on the credibility of financial accounting information. The aim of this study investigates the impact of the mandatory adoption of IFRS on earnings quality in term of earnings management and accounting conservatism in consideration of eleven European countries (Germany, France, Italy, The Netherlands, Spain, Sweden, Switzerland, Portugal, Belgium, Norway and the United Kingdom) as a sample study. Then to test whether investors could predict a company's future performance efficiently based on deferred tax expense as one of the accruals components before and after the mandatory adoption of IFRS. Since the mandatory adoption of International Financial Reporting Standards (IFRS) required by the European Union (EU) Parliament, numerous research studies have examined whether earnings management has been reduced due to the mandatory adoption. Chapter two of this study examines whether the board of directors is more effective in constraining earnings management after the mandatory application of IFRS. More specifically, the study explored ways that two board characteristics, board independence and the existence of an audit committee, have impacted earnings management since 2005. The empirical results with eleven European countries (Germany, France, Italy, The Netherlands, Spain, Sweden, Switzerland, Portugal, Belgium, Norway and the United Kingdom) showed evidence of an inverse relationship between the strength of corporate governance and the extent of earnings management. This negative association suggests that firms that apply IFRS with a high level of corporate governance standards are less likely to be involved in earnings management. This study indicates that board independence and the existence of audit committees play important and effective roles in reducing earnings management after the introduction of IFRS. The results also provide evidence that the internationally uniformed accounting regulatory framework significantly contributes to the effectiveness of the two corporate governance mechanisms. Chapter three examines the impact of the mandatory IFRS adoption on the asymmetrically timely gain and loss recognition (accounting conservatism). The findings provide evidence of the importance of the mandatory adoption of IFRS in increasing of accounting conservatism in pooled samples and separate samples. Chapter four investigates whether investors could predict a company's future performance efficiently based on deferred tax expense as one of the accruals components before and after the mandatory adoption of IFRS. Moreover, whether or not the predictions could be generalised to other European countries was examined. The results imply that an accrual anomaly exists in pooled samples before and after mandatory IFRS adoption and the study prove that deferred tax expense as a determinant factor of accounting accruals is overweighed by stocks prices before and after IFRS adoptions.
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Dinh, Hai-Dung [Verfasser], and Günter [Akademischer Betreuer] Schmidt. "Optimization in finance : approaches for modeling and solving the multi-period loss offset problem in German income tax system / Hai-Dung Dinh. Betreuer: Günter Schmidt." Saarbrücken : Saarländische Universitäts- und Landesbibliothek, 2015. http://d-nb.info/1072620421/34.
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Dinh, Hai-Dung Verfasser], and Günter [Akademischer Betreuer] [Schmidt. "Optimization in finance : approaches for modeling and solving the multi-period loss offset problem in German income tax system / Hai-Dung Dinh. Betreuer: Günter Schmidt." Saarbrücken : Saarländische Universitäts- und Landesbibliothek, 2015. http://nbn-resolving.de/urn:nbn:de:bsz:291-scidok-61545.
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Gonzáles, Laca Carlos Miguel, and Faustor Carmen Jahaira Denise Villanueva. "Analysis of Article 159 of the Tax Code: An Appointment on the Denaturalization of the Counterclaim." Derecho & Sociedad, 2015. http://repositorio.pucp.edu.pe/index/handle/123456789/118818.
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In the first part of the article, a development for the concepts of provisional remedies and real or personal property bond and covering loss and damage, is proposed, under the Constitutional Court and our national doctrine view; as well as the scope of the first as a fundamental right, and second as a condition of execution. On the following part of the paper, the inclusion and the subsequent amendments to the article 159° of Tax Code is exposed, also its scopes and reasons. Finally, a possible modification of the article, that respect state´s raising goals and due process citizens’ right, is proposed.El presente artículo desarrolla los conceptos de medida cautelar y contracautela, a la luz de lo resuelto por el Tribunal Constitucional y lo establecido por nuestra doctrina, así como los alcances del primero como derecho fundamental y del segundo como requisito de ejecución. De la misma forma, se analiza los alcances de la incorporación del artículo 159° del Código Tributario, mediante Decreto Legislativo N° 1121, y su modificatoria a través de la Ley N° 30230. Finalmente, se propone una posible modificación al mencionado artículo, de conformidad con los fines recaudatorios del Estado y el derecho a la tutela jurisdiccional efectiva de los administrados.
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Andersson, Hilda, and Gustafsson Lina Nygren. "Utredning av stopptider i ett täcklacksmåleri verksamt inom fordonsindustrin." Thesis, Högskolan i Jönköping, Tekniska Högskolan, 2019. http://urn.kb.se/resolve?urn=urn:nbn:se:hj:diva-45273.
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The purpose of this study is to investigate and analyze stops that occur in the painting process of trucks; specifically related to the buffer system after the top coat process. Based on this investigation, improvements are presented in order to eliminate stops and improve overall assembly time. With this scope in mind, the following issues have been raised: 1. What are the root causes for stops in the buffer system? 2. How much can corrective maintenance be reduced? 3. What potential savings are achieved by reducing or eliminating stops in the buffer system? 4. How would reducing stops increase the availability for the top coat paint shop? A case study has been performed where historical data has been analyzed and staff from the production, maintenance and IT departments have been interviewed. The analyzed data along with a theoretical framework are the basis for the suggested actions that will improve flows through the top coat production. The result indicates that a great part of the delays related to the buffer system are caused by soft losses. The stops are the results of: Lack of a distinct set of rules for how data and software may be used Lack of communication between the workshops The implications of these delays are: increased costs and reduced efficiency of the production line. The purposed actions presented in the study gives the company opportunity to achieve full capacity, eliminate delays and increase overall efficiency. The study is limited to the top coat paint shop and does not include the primary paint shop or final assembly. The results, analysis and suggestions presented in the study includes the soft losses that causes stop in the buffer system.Syftet med följande studie är att undersöka och analysera stopp och dess rotorsaker som uppkommer i buffertsystemet på ett täcklacksmåleri. Utifrån denna utredning presenteras sedan åtgärdsförslag i syfte att eliminera undersökta stopp. För att kunna uppfylla syftet med studien har följande frågeställningar formulerats: Vad finns det för stopp relaterade till buffertsystemet och vad är rotorsakerna till dessa? Hur mycket kan det akuta underhållet reduceras? Hur stora besparingar skulle företaget kunna göra genom reducering eller eliminering av stoppen? På vilket sätt kan en minskning av stoppen öka tillgängligheten för täcklacksmåleriet? En fallstudie har genomförts där historisk data har analyserats och personal från avdelningar som produktion, underhåll och IT har intervjuats. Den empiri som samlats in tillsammans med det teoretiska ramverket som presenteras i rapporten ligger till grund för resultatet, analysen och åtgärdsförslagen. Resultatet från studien visar att en stor andel av de stopp som sker i buffertsystemet orsakas av mjuka förluster. Dessa stopp är en konsekvens av bristfällig hantering av data och mjukvara samt bristfällig kommunikation mellan verkstäderna. Konsekvenserna av dessa stopp resulterar i ökade kostnader samt en nedsatt effektivitet för täcklacksmåleriet. Åtgärdsförslagen som presenteras ger företaget goda möjligheter att uppnå sin fulla kapacitet, eliminera stoppen och därmed öka effektiviteten. Studien är avgränsad till måleriprocessen och omfattas inte av grundmåleriet eller monteringen. De resultat, analyser och åtgärdsförslag som presenteras är avgränsade till de mjuka förlusterna som orsakar stopp i buffertsystemet.
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Malek, Elham, and Halldén Monica Dias. "Handelsbolagslösningen : Ett skatteupplägg där näringsfastigheter avyttras paketerade i svenska handelsbolag ägda av nederländska juridiska personer." Thesis, Jönköping University, JIBS, Commercial Law, 2006. http://urn.kb.se/resolve?urn=urn:nbn:se:hj:diva-666.
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Det har på senare tid uppmärksammats att svenska fastighetsbolag paketerar näringsfastigheter i svenska handelsbolag med utländska juridiska personer som delägare. Detta fenomen är ett skatteupplägg som kallas för handelsbolagslösningen. I uppsatsen utgår vi från ett typfall där delägarna i det svenska handelsbolaget är nederländska juridiska personer. Skatteupplägget inbegriper tre transaktionsled, där det första ledet innebär att ett säljande svenskt aktiebolag underprisöverlåter en näringsfastighet till det svenska handelsbolaget. Det andra ledet är att de nederländska delägarna avyttrar sina andelar i det svenska handelsbolaget samt fastigheten, det vill säga fastighetspaketet, till ett utomstående köpande aktiebolag i Sverige. Slutligen, efter köpet, likviderar det köpande aktiebolaget handelsbolaget och skiftar ut fastigheten till sig. Problematiken kring skatteupplägget handelsbolagslösningen är att det svenska aktiebolaget har tillgodoräknat sig fastighetens dolda värde, utan skattekonsekvenser, genom en förvärvad skattefri utdelning från de nederländska delägarbolagen. Det köpande aktiebolaget har samtidigt erhållit kapitalförlustavdrag i Sverige, som innebär att förlusten kan kvittas mot motsvarande kapitalvinster inom bolaget, och därmed minskas det skattemässiga underlaget. I samband med fastigheters långa avskrivningsperiod får dessa paketeringar stor ekonomisk betydelse. Frågan som uppstår är huruvida handelsbolagslösningen är lagenlig. Utifrån en rättsdogmatiskmetod behandlar vi problematiken genom en stegvis bedömning av transaktionerna.
I samband med första steget i handelsbolagslösningen behandlar vi huruvida överlåtelsen av fastigheten från det säljande svenska aktiebolaget till det svenska handelsbolaget uppfyller villkoren för en kvalificerad underprisöverlåtelse. Vi finner att underprisöverlåtelsen är kvalificerad och att uttagsbeskattning således inte inträder. I det andra steget uppkommer frågan om de nederländska delägarbolagen blir skatteskyldiga i Sverige för den kapitalvinst som uppkommer på de avyttrade andelarna i det svenska handelsbolaget. Utifrån förutsättningar och resonemang i rättsfall, kommer vi fram till att det inte föreligger någon skatteskyldighet i Sverige för de nederländska delägarna. I det tredje steget och sista steget ställs vi inför frågan om det köpande svenska aktiebolaget i samband med upplösningen av det svenska handelsbolaget har rätt att dra av den kapitalförlust som uppstår på andelarna. Bedömningen sker utifrån om förlusten kan anses vara verklig eller inte. Med stöd av praxis anser vi att kapitalförlusten är verklig och därmed avdragsgill.
I vår rättsutredning av de tre olika transaktionsleden, finner vi att dessa följer gällande rätt. Med beaktande av detta anser vi det vara av vikt att undersöka huruvida skatteflyktslagen kan tillämpas på typfallet. Med stöd av gällande rätt bör skatteflyktslagen inte bli tillämplig på det köpande svenska aktiebolagets taxering. Vi klargör istället om skatteflyktslagen kan angripa det säljande svenska aktiebolaget. I vår utredning finner vi att skatteflyktslagen inte är tillämplig på handelsbolagslösningen så som den artar sig i typfallet. Detta med stöd av vår gjorda rättsutredning samt de spekulationer som finns på området.
Vår slutsats är att det blir svårt att angripa de fastighetsbolag som har utnyttjat handelsbolagslösningen, åtminstone utifrån den konstruktion som föreligger i typfallet. Utifall det är lagstiftarens intention att förhindra denna typ av skatteupplägg, är det upp till denne att komma med ny lagstiftning som tar fasta på problematiken.
Swedish real estate companies have attracted a lot of attention by packaging industrial real estate in general partnership companies that are owned by foreign legal entities. This tax arrangement is a phenomenon that is referred to as the general partnership solution. In this thesis, we use a case example in which the partners in the Swedish general partnership are legal entities with Dutch nationality. The tax arrangement includes three transaction phases, where the first involves an under priced transfer of a commercial real estate from the selling Swedish private limited company to the Swedish general partnership. In the second phase, the Dutch partners trade their shares in the Swedish general partnership including the real estate to an external buying private limited company in Sweden. After the trade the buying Swedish private limited company liquidates the general partnership and transfer the real estate from the general partnership to itself. As a result of this tax arrangement a complex problematic arises when the Swedish private limited company obtain the hidden value in the real estate by receiving tax-free dividends from the Dutch partner companies. The buying Swedish private limited company simultaneously receive capital deficit tax deductions in Sweden, which means that losses can be settled by corresponding capital profits within the company, consequently reducing their tax base. The long depreciation period of real estates means that packaging represents great economical significance. The question that arises is whether the general partnership solution is consistent with Swedish law. Based on a juridical dogmatic method, we consider this complex of problems by means of a systematic assessment of the discussed transactions.
In the first step of the general partnership solution, we consider whether the transfer of real estate from the selling Swedish private limited company fulfils the conditions for a qualified under priced transfer. We find that the under priced transfer is qualified, and therefore withdrawal taxation does not occur.
In the second step, the arising question is whether the Dutch partner companies become liable for taxation in Sweden for capital profit generated from the disposed shares in the Swedish general partnership. According to the prerequisites and reasoning in legal cases, we find that tax liability in Sweden does not arise for the Dutch partners. In the third and final step, we are faced with the question whether the buying Swedish private limited company has the legal right to deduct the capital loss that results from the Swedish general partnership resolution. The assessment is based on whether the loss can be considered genuine. In accordance with case law we regard the capital loss genuine and therefore tax-deductible.
In our legal inquiry we conclude that the three different transaction phases comply with Swedish law. Considering this, we find it imperative to examine whether the Swedish tax evasion law can apply in the case example. By virtue of domestic law, it is not probable that the tax evasion law can apply on the buying Swedish private limited company’s taxation. In regards to the seller’s taxation, we clarify whether the tax evasion law can be applicable concerning the selling Swedish private limited company. We find that the tax evasion law is not applicable in the general partnership solution, in the form that it has in the case example. We support this statement with reference to our legal inquiry and referring to some speculations on the subject.
Our conclusion is that it would be difficult to deal with the real estate companies that have made use of the general partnership solution, at least in the construction that exists in the case example. It is up to the legislator to decide on whether to prevent this type of tax arrangement or not.
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Anderson, Seona Margaret. "Loss and change : a social history of wild plant use in Taz, Udege and Nanai communities of the Russian Far East." Thesis, University College London (University of London), 2002. http://ethos.bl.uk/OrderDetails.do?uin=uk.bl.ethos.272159.
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Bian, Tao [Verfasser]. "Numerical and Experimental Investigations of Flow Loss and Flow Structure of Circular Arc Cascades with Different Leading and Trailing Edges / Tao Bian." Aachen : Shaker, 2018. http://d-nb.info/1188548395/34.
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Bakran, Rebecka, and Erica Mattsson. "Föräldrars användning av barnriktat tal : En utvärdering av PEPP-modellensbedömningsmetoder; LENA- och videoinspelning." Thesis, Uppsala universitet, Blom Johansson: Logopedi, 2021. http://urn.kb.se/resolve?urn=urn:nbn:se:uu:diva-430231.
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Objective and aim: Adults use child-directed-speech in their interaction with infants,w hich has been confirmed to have positive effects on their language learning. This study was a part of the Words make a difference project at Karolinska Institutet (KI). Within this project, a new intervention model has been developed for caregivers of children with a hearing impairment, called the Prevention Education Program forParents (PEPP). The purpose of the present study was to investigate whether caregiver’s use of child-directed speech differed between a structured play situation and in home environment. The aim was also to evaluate the PEPP model's methods of analysis; video and LENA-recording, concerning measurement of child-directed speech in a structured play situation. Data from the present study were also collected as reference data for the Words make a difference. Methods: The study involved four families with typically hearing infants aged 0-7months and their caregivers. Data collection was undertaken using PEPP's evaluation methods in a short, structured play situation and a full day recording in a home environment. Results and conlusion: In some cases, the care-givers’ use of child-directed speech differed between the structured play situation and the full-day recording in the home environment. The two data collection methods (audio recording and video recording) during the structured play situation were in good agreement regarding the use of child directed speech. The conclusion is that the PEPP model is a functional method for examining the spoken language environment of infants. Bakgrund och syfte: Barnriktat tal (BRT) används av vuxna i samspel med små barn och har visat sig innebära positiva effekter för språkinlärningen. Denna studie var en del av Ord gör skillnad- projektet på Karolinska Institutet (KI) där en ny interventionsmodell för föräldrar till barn med hörselnedsättning utvecklas: Prevention Education Program for Parents (PEPP). Den aktuella studiens syfte var att undersöka spädbarns talspråksmiljö och om föräldrars användning av BRT skiljer sig mellan en strukturerad leksituation och i hemmiljö. Syftet var också att utvärdera PEPP- modellens bedömningsmetoder; LENA-inspelning och videoinspelning. Metod: I studien deltog fyra normalhörande spädbarn i åldrarna 0-7 månader och deras mammor. Datainsamlingen gjordes med hjälp av PEPP:s bedömningsmetoder dels under en kort strukturerad leksituation dels genom en heldagsinspelning i hemmiljö. BRT analyserades utifrån fem språkspecifika särdrag; segmentell fonologi, prosodi, syntax, ordförråd och pragmatik. Resultat och slutsatser: Användning av BRT skiljde sig i enstaka fall mellan den strukturerade leksituationen och heldagsinspelningen i hemmiljö. De två bedömningsmetoderna stämde väl överens med avseende på användningen av BRT under den strukturerade leksituationen. Slutsatsen är att PEPP-modellens bedömningsmetoder är användbara vid undersökning av talspråksmiljön hos spädbarn i åldrarna 0-7 mån gällande BRT och kan med fördel användas i föräldrahandledning. Resultaten från den här studien kan komma att användas för metodutveckling av PEPP- modellen och även som referensdata till Ord gör skillnad- projektet.
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Araújo, Evaristo Donato. "A taxa de recuperação de créditos ruins em bancos comerciais privados brasileiros." reponame:Repositório Institucional do FGV, 2004. http://hdl.handle.net/10438/2457.
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Previous issue date: 2004-04-07T00:00:00ZCredit risk comes from the possibility of the debtor not paying its debt at the maturity date, and the promised amount. When the debtor doesn’t pay in full its debt, we say he or she is in default. In this case, the creditor gets a loss. However, the loss could be reduced if the debtor pays part of his or her debt. The measurement of a debtor’s probability of default has been the subject of studies for decades. However, the measurement of how much one can receive from a defaulted credit – the recovery rate – has been given attention only recently. And, most of the time, this measure has been calculated for huge companies in United States financial markets, only. We have defined recovery rate based on financial reports of Brazilian commercial banks, and tracked the path of this variable pari passu to default rate, defined from the same reports also. We established a theoretical framework, and made hypothesis on how such variables as default rates and other credit quality indicators, economic level indicators, nominal and real interest rates, and capital markets indicators could explain variations on the recovery rates we have defined. We gathered information from 46 Brazilian private commercial banks, semiannually, bracing the period between June of 1994 and December 2002. These institutions were segmented by their share on the amount of credit of the private banking industry in Brazil and by the origin of its capital. Statistical models were run on explanatory variables based on original data and on variables obtained from principal components analysis. The models were able to explain most of the variation observed on the recovery rate we have defined, for the segments we have studied. The best models have shown that variations on the recovery rate could be explained by default rates and other indicators of credit quality, economic activity indicators and capital markets indicators.
O risco de crédito decorre da possibilidade de o devedor não honrar sua dívida no montante e na data aprazada. Quando o devedor não liquida sua dívida nas condições contratadas, diz-se que se torna inadimplente. Neste caso, o credor incorre em prejuízo. A perda, entretanto, pode ser reduzida se o cliente pagar parcialmente o que deve. A mensuração da probabilidade de um devedor inadimplir tem sido objeto de estudos há décadas. Entretanto, a quantificação do quanto o credor recebe em caso de inadimplência – a taxa de recuperação –só recentemente tem recebido atenção da academia. E, na maioria das vezes, esta quantificação tem-se limitado aos títulos de grandes empresas, negociados no mercado de capitais dos Estados Unidos da América. Neste trabalho, definiu-se uma taxa de recuperação baseada em informações contábeis de instituições bancárias brasileiras e analisou-se o comportamento desta variável pari passu à taxa de inadimplência, também definida a partir de dados contábeis. Estabeleceu-se um arcabouço teórico capaz de explicar de que forma variáveis como a taxa de inadimplência e outros indicadores de qualidade das carteiras de crédito, indicadores da atividade econômica, níveis de juros nominais e reais e indicadores do mercado de capitais, poderiam explicar as variações na taxa de recuperação das carteiras de crédito. Foram obtidas informações de um conjunto de 46 instituições bancárias privadas brasileiras, semestralmente, para o período compreendido entre junho de 1994 e dezembro de 2002. Essas instituições foram segmentadas pela representatividade de suas carteiras de crédito no volume total de créditos das instituições comerciais brasileiras e por origem de seu capital acionário. Elaboraram-se modelos estatísticos baseados em regressões multivariadas tanto de variáveis originais como de variáveis obtidas através de análise de componentes principais, que se mostraram capazes de explicar parte considerável das variações observadas na taxa de recuperação no conceito contábil, para os vários segmentos de instituições estudados. Mostraram-se como variáveis explicativas relevantes, nos melhores modelos, indicadores de inadimplência, indicadores da atividade econômica e indicadores do mercado de capitais.
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Carvalho, Ana Lúcia. "Fatores que influenciam o sucesso de um programa de transferência de embriões equinos." Master's thesis, Universidade Técnica de Lisboa. Faculdade de Medicina Veterinária, 2012. http://hdl.handle.net/10400.5/4849.
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Dissertação de Mestrado Integrado em Medicina VeterináriaO sucesso de um programa comercial de transferência de embriões depende principalmente da interação dos fatores que afetam a recolha embrionária, a gestação e a morte embrionária após a transferência. O objetivo deste trabalho consistiu na avaliação de alguns destes fatores, de forma a minimizar aqueles que possam ter uma influência negativa e permitindo também informar e aconselhar os proprietários dos animais de uma forma mais clara e correta. O presente estudo foi realizado na Central Equina de Reprodução, no estado de São Paulo, Brasil. Foram analisados os dados relativos a 2086 recolhas e 1090 transferências, efetuadas ao longo de duas épocas reprodutivas consecutivas. Neste trabalho, foi avaliada a influência na taxa de recolha embrionária, da época reprodutiva, do dia da recolha, do tipo de sémen (refrigerado ou congelado) utilizado na inseminação artificial e da raça da dadora. Relativamente às taxas de gestação e de morte embrionária, foi avaliada a influência da época reprodutiva, da idade do embrião, da ciclicidade (recetoras cíclicas e acíclicas) e do dia pós-ovulação em que a recetora se encontrava no dia da transferência. As variáveis foram analisadas pelo teste de Fisher ou Qui-quadrado em tabelas de contingência 2x2, sendo as diferenças consideradas significativas se p <0,05. O tipo de sémen teve uma influência significativa na taxa de recolha embrionária. Foi possível concluir que em éguas inseminadas com sémen congelado a taxa de recolha embrionária é menor (p <0,05), sendo por isso preferível utilizar sémen fresco ou refrigerado. A época reprodutiva afetou significativamente a taxa de gestação, tendo esta sido superior no ano de 2011-2012 (p <0,05). No entanto, em ambas as épocas reprodutivas, as taxas de gestação foram consideradas satisfatórias, sendo de 76,0% em 2010-2011 e de 81,8% em 2011-2012. Tanto a idade do embrião como a ciclicidade e o dia pós-ovulação da recetora não influenciaram as taxas de gestação nem as de morte embrionária. Estes resultados permitem concluir que é possível transferir embriões entre os 6 e os 10 dias de idade, utilizar éguas recetoras entre os 3 e os 9 dias pós-ovulação bem como éguas em anestro suplementadas com progesterona de longa ação, sem que isso afete o sucesso do programa de transferências.
The success of a commercial embryo transfer program depends mainly on the interaction of factors that affect embryo recovery, pregnancy and embryonic loss after the embryo transfer. The objective of this study was to evaluate these factors, allowing us to minimize the ones that can have a negative influence, and simultaneously to correctly inform and give advice to animal owners. Data of 2086 collections and 1090 transfers made over two consecutive breeding seasons in the Central Equina de Reprodução in the state of São Paulo, Brazil were analysed. In this study, it was assessed the influence of reproductive season, collection day, type of semen used in artificial insemination (cooled or frozen), and donor breed in the embryo recovery rate. Regarding pregnancy and embryonic loss rates, the influence of breeding season, embryo age, cyclicity (cyclic and noncyclic recipients mares), and post ovulation day the recipient was on the transfer day, were assessed. The variables were statistically analysed according to the Fisher test or Chi Square in 2x2 contingency tables, in which the differences were held as significant if p<0.05. The type of semen was the only factor that had a significant influence on embryo recovery rate (p<0.05). Mares inseminated with frozen semen showed an embryo recovery rate lower than the rate obtained from mares inseminated with cooled semen. The pregnancy rate was affected only by the breeding season (p<0.05). However, in both breeding seasons the pregnancy rates were viewed as satisfactory, being 76.0% in 2010-11 and 81.8% in 2011-2012. The embryo’s age as well as the cyclicity and the recipient’s post ovulation day did not influence either pregnancy or embryonic loss rates. These results demonstrate that it is feasible to transfer embryos between the 6th and 10th days of age, to use recipient mares between the 3rd and 9th day post ovulation, as well as mares without ovarian cyclic activity treated with long acting progesterone, without endangering the success of the transfer program.
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Silva, Claudio Galeno Piantino e. "Efeitos de um protocolo de exercício físico regular sobre a taxa de perda de peso, composição corporal e capacidade antioxidante total de cães obesos." Universidade de São Paulo, 2018. http://www.teses.usp.br/teses/disponiveis/10/10135/tde-17082018-122645/.
Full textAbstract:
A obesidade é a afecção nutricional e metabólica mais comum nas sociedades desenvolvidas. O aumento dos depósitos corporais de gordura estão relacionados à alterações de funções fisiológicas e distúrbios que levam a queda na qualidade e expectativa de vida dos cães. A atividade física é de suma importância, uma vez que aumenta o gasto energético e pode auxiliar na prevenção da perda de massa magra durante o regime. Esse estudo avaliou a efetividade da prática de exercícios físicos regulares na taxa de perda de peso, composição corporal, potencial antioxidante, glicemia e insulinemia de cães obesos em restrição energética. Vinte cães obesos, de ambos os sexos e com índice de gordura corporal mínimo de 50 (Hills, 2013), participaram desse estudo e foram divididos em 2 grupos de 10 animais cada, G1 e G2. Todos os cães foram colocados em um mesmo protocolo de regime alimentar para perda de 20% do seu peso inicial. Ao G1 não foi recomendada a associação com exercícios, diferente do G2, cujo protocolo estabelecia atividade física em hidroesteira, três vezes por semana, durante 30 minutos. No início e no final do estudo foram analisados contagem total sanguínea, bioquímica, triglicérides, colesterol, funções renal e hepática, concentrações plasmáticas de glicose e insulina, avaliação da resistência insulínica através do índice HOMA e capacidade antioxidante total. O G2 apresentou maior porcentagem de massa muscular ao término do estudo em comparação ao G1 (p<0,05), no entanto, não houve diferença na taxa de perda de peso semanal entre os grupos (p>0,05). A prática de atividade física resultou em melhora da sensibilidade insulínica verificada pela redução do índice HOMA (p<0,05). Não foram observadas diferenças nas demais variáveis avaliadas. Concluiu-se que a asociação da restrição energética com a prática de atividade física regular resultou em melhores benefícios para a saúde dos cães.Obesity is the most common nutritional and metabolic disorder in developed societies. Increases in body fat deposits are related to changes in physiological functions and disorders that lead to dogs quality and expectancy of life falls. Physical activities are of utmost importance as they increase energy expenditure and help in preventing lean mass losses during the diet. This study evaluated the effectiveness of regular exercise in the weight loss rate, body composition, antioxidant potential, glycemia and insulinemia in obese dogs. Twenty obese dogs of both sexes and with a body score of 50 or 60 according to the Hill\'s® Body Fat Index, participated in this study and were divided into 2 groups of 10 animals each, named G1 and G2. All dogs were allocated in the same diet protocol for loss of 20% of their initial body weight. using the same diet. All of them used the same diet, and Hill\'s r/d was the elected one. A weight loss protocol with physical activity was not imposed to G1 group, in contrast to the established protocol for G2 group that established physical activity in a water treadmill. At the beginning and at the end of the study, total blood counts, biochemistry, triglycerides, cholesterol, renal and hepatic function, plasma glucose and insulin concentrations, and HOMA index and total antioxidant capacity were evaluated. G2 presented a higher percentage of muscle mass at the end of the study compared to G1 (p <0.05); however, there was no difference in the weekly weight loss rate between groups (p> 0.05). The practice of physical activity resulted in an improvement in the insulin sensitivity of the HOMA index (p <0.05). No differences were observed in the other variables evaluated. It was concluded that the association of energy restriction with the practice of regular physical activity resulted in better health benefits for dogs.