Miracle-dz/UniFAR-FTUs huggingface dataset:
Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations

The OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations provide guidance on the application of the “arm’s length principle”, which is the international consensus on transfer pricing, i.e. on the valuation, for tax purposes, of cross-border transactions between associated enterprises. In a global economy where multinational enterprises (MNEs) play a prominent role, transfer pricing is high on the agenda of tax administrators and taxpayers alike. Governments need to ensure that the taxable profits of MNEs are not artificially shifted out of their jurisdictions and that the tax base reported by MNEs in their respective countries reflects the economic activity undertaken therein. For taxpayers, it is essential to limit the risks of economic double taxation that may result from a dispute between two countries on the determination of an arm’s length remuneration for their cross-border transactions with associated enterprises.
Isolation and Characterization of High-Osmolarity-Sensitive Mutants of Fission Yeast

ABSTRACT For the fission yeast Schizosaccharomyces pombe, adaptation to high-osmolarity medium is mediated by a mitogen-activated protein (MAP) kinase cascade, involving the Wis1 MAP kinase kinase and the Sty1 MAP kinase. The MAP kinase pathway transduces an osmotic signal and accordingly regulates the expression of the downstream target gene (gpd1+) that encodes NADH-dependent glycerol-3-phosphate dehydrogenase, in order to adaptively accumulate glycerol inside the cells as an osmoprotectant. We previously characterized a set of high-osmolarity-sensitive S. pombemutants, including wis1, sty1, andgpd1. In this study, we attempted to further isolate novel osmolarity-sensitive mutants. For some of the mutants isolated, profiles of glycerol production in response to the osmolarity of the growth medium were indistinguishable from that of the wild-type cells, suggesting that they are novel types. They were classified into three distinct types genetically and, thus, were designated hos1,hos2, and hos3 (high osmolarity sensitive) mutants. One of them, the hos1 mutant, was characterized in detail. The hos1 mutant was demonstrated to have a mutational lesion in the known ryh1+ gene, which encodes a small GTP-binding protein. Disruption of theryh1+ gene results not only in osmosensitivity but also in temperature sensitivity for growth. It was also found that the Δryh1 mutant is severely sterile. These results are discussed with special reference to the osmoadaptation of S. pombe.
Parity and cancer risk in slovakia

Mortality data from women aged 45‐74 who died between 1968 and 1977 in Slovakia, Czechoslovakia, were used to examine the effect of parity (number of live‐born children) on risk of dying from each of 20 common cancers. After controlling for the effects of age and year of death, the effect of parity on risk was statistically significant at the p < 0.001 level, for cancers of the stomach, liver, gall‐bladder, breast, cervix, and ovary; and at the p < 0.01 level for uterine corpus and brain. No effect of parity was seen for cancer of the colon or rectum. Among parous women the trend relating risk to level of parity was significant at the p < 0.001 level for cancers of the breast, uterine corpus, ovary and brain; and at the p < 0.01 level for stomach cancer. The findings relating parity to cancers of the breast and reproductive organs are consistent with previous reports. The associations of parity with cancers of the digestive tract deserve further study.
Effects of contact network structure on epidemic transmission trees: implications for data required to estimate network structure

Understanding the dynamics of disease spread is key to developing effective interventions to control or prevent an epidemic. The structure of the network of contacts over which the disease spreads has been shown to have a strong influence on the outcome of the epidemic, but an open question remains as to whether it is possible to estimate contact network features from data collected in an epidemic. The approach taken in this paper is to examine the distributions of epidemic outcomes arising from epidemics on networks with particular structural features to assess whether that structure could be measured from epidemic data and what other constraints might be needed to make the problem identifiable. To this end, we vary the network size, mean degree, and transmissibility of the pathogen, as well as the network feature of interest: clustering, degree assortativity, or attribute‐based preferential mixing. We record several standard measures of the size and spread of the epidemic, as well as measures that describe the shape of the transmission tree in order to ascertain whether there are detectable signals in the final data from the outbreak. The results suggest that there is potential to estimate contact network features from transmission trees or pure epidemic data, particularly for diseases with high transmissibility or for which the relevant contact network is of low mean degree. Copyright © 2017 John Wiley & Sons, Ltd.
Diffusion imaging in multiple sclerosis: research and clinical implications

Multiple sclerosis (MS) is an inflammatory‐demyelinating and neurodegenerative disease of the central nervous system (CNS) and the most frequent cause of non‐traumatic disability in young and middle‐age adults. Although conventional MRI (including T2‐weighted, pre‐ and post‐contrast T1‐weighted scans) has had a huge impact on MS by enabling an earlier diagnosis, and by providing surrogate markers for monitoring treatment response, it is limited by the low pathological specificity and the low sensitivity to diffuse damage in normal‐appearing white matter and gray matter. Diffusion weighted MRI is a quantitative technique able to overcome these limitations by providing markers more specific to the underlying pathologic substrates and more sensitive to the full extent of ‘occult’ brain tissue damage. This review describes diffusion studies in MS, discusses their pathophysiological implications and emphasizes their clinical relevance. Copyright © 2010 John Wiley & Sons, Ltd.
Paraoxonase 1 , total cholesterol and HDL cholesterol in diabetes mellitus

Background: Diabetes mellitus (DM) refers to a group of common metabolic disorder that shares the phenotype of hyperglycemia. The existence of hyperglycemia produces increased oxidative stress and associated with an increased risk of cardiovascular disease (CVD). The present study was planned to measure the serum levels of paraoxonase 1 (PON 1) activity, total and high density lipoprotein (HDL) cholesterol in patients with type 2 diabetes mellitus and to compare with healthy controls. Material and Methods: In this study total 80 subjects were included above 40 years of age. 40 clinically diagnosed type 2 diabetic patients and 40 normal subjects were recruited as control. PON 1 activity , total cholesterol and HDL cholesterol levels were measured by the methods of Therry FD et al and Lopes Virella M et al respectively.Data were analyzed using‘t’ test for their level of significance. Results:The mean PON 1 activity in type 2 diabetic patients was significantly lower than in the controls. The mean total cholesterol levels were significantly higher in patients as compared to the control subjects while the mean value of HDL cholesterol was significantly lower in type 2 diabetics when compared with controls. Conclusions: Reduced serum PON 1 activity, HDL cholesterol and elevated total cholesterol level might contribute to the increased susceptibility for the development of CVD in type 2 diabetic patients. Key-words: Type 2 diabetes mellitus, PON 1, HDL cholesterol Introduction The prevalence of type 2 diabetes mellitus is increasing and by the year 2025, the total number of people with diabetes is projected to reach 330 million worldwide. The region most likely to experience the main brunt of the epidemic is Asia. Here, diabetes could become two or three times more common than it is at present. Over the next 25 years, India alone is expected to see an increase from 36 to 73 million people with diabetes; majority of the cases being type 2 diabetes mellitus.
Enhancing quality management of fresh fish supply chains through improved logistics and ensured traceability

The aim of the project was to enhance product quality management in fresh fish supply chains through improved logistics management and ensured traceability effectiveness. The study provides insights into seafood companies’ perspectives on the benefits of implementing traceability. Knowledge on the net benefits of implementing traceability and the distribution of costs and benefits among actors can support decision making. Comprehensive literature review on the necessary components to ensure traceability and a framework developed to assess traceability system effectiveness enable researchers and practitioners in the food/seafood sector to locate problems and take necessary actions to ensure effective traceability. In addition, more efficient use of recorded data provides an approach to enhance quality management. Data on ambient temperatures during logistics steps can be used to calculate the product warm up time. The results on temperature profiling pinpointed several hazardous steps in air transportation related to handling, storage and transport operations. Pros and cons of two transport modes, air vs. sea, were analysed. Several factors were found to influence product temperature and shelf life during logistics processes, namely, presence/absence of precooling, mode of transport, product location and logistics length. These findings help to improve logistics management as well as to make decisions on transport alternatives so as to improve quality management. The new photochromic time-temperature indicator (TTI) was found to give reproducible responses and reflect well the temperature conditions of fresh fish supply chains. The results show that a right charging time could be defined to suit the shelf life of the fresh fish product concerned. The TTI of a right charging level placed on the bottom surfaces of fresh cod retail packs was found to reflect well the temperature conditions of the product and the shelf life declared by sensory evaluation, except for the case of severely superchilled conditions, and other methods of quality control. The results indicate the potential of using the new TTI to continuously monitor product temperature history, quality and shelf life in fresh fish supply chains.
Free Cash-Flow, Issuance Costs and Stock Price Volatility

We study the issuance and payout policies that maximize the value of a firm facing both agency costs of free cash-flow and external financing costs. We find that the firm optimally issues equity. Equity distributes no dividends until a target cash level is reached, while new equity is issued when the firm runs out of cash. We characterize the process modelling the number of outstanding shares and the dynamics of the stock prices. In line with the leverage effect identified by Black (1976), we show that both the volatility of stock returns and the dollar volatility of stock prices increase after a negative shock on stock prices.
Noise Floor Reduction of an Er:Fiber Laser-Based Photonic Microwave Generator

The generation of microwaves from optical signals suffers from thermal and shot noise inherent in the photodetection process. This problem is more acute at lower pulse repetition rates where photodiode saturation limits the achievable signal-to-noise ratio. In this paper, we demonstrate a 10-15-dB reduction in the 10-GHz phase noise floor by multiplication of the pulse repetition rate. Starting with a 250-MHz fundamentally mode-locked erbium (Er):fiber laser, we compare the following two different approaches to repetition rate multiplication: 1) Fabry-Perot cavity filtering and 2) a cascaded, unbalanced Mach-Zehnder (MZ) fiber-based interferometer. These techniques reduce the phase noise floor on the 10-GHz photodetected harmonic to -158 and -162 dBc/Hz, respectively, for Fourier frequencies higher than 100 kHz.
The Core of Corporate Governance: Implications of the Takeover Directive for Corporate Governance in Europe

Corporate governance as a term encompasses the governance of companies and, as such, covers a broad area. The current mainstream corporate governance debate tends primarily to address the relationship between the company and the shareholders and, more specifically, the election, dismissal and functioning of the board and top management. This paper uses corporate governance in the broader sense. The governance of companies, these all-important components of our market economies, is crucial to the further development of our economies and to the achievement of our societal goals. In the broader sense of corporate governance, the function of the board (and top management) is a highly significant issue, as is their relationship with the employees. Together they are the essence of the company and those parties on which the performance of the company most crucially depends. The board has a unique role and position in balancing the involved interests – and promoting the interests of the company. Accordingly, the interests of the company form the guideline in accordance with which the board is meant to govern the company. The concept of the ‘interests of the company’– or just the ‘company interest’, as it is known in Continental Europe – has traditionally been viewed quite differently in the various jurisdictions, with Germany and the UK generally being perceived as occupying opposite ends of the spectrum. The possible effect of the Takeover Directive on the development of the concept of the company interest and on the functioning of the board constitutes the core of this paper's analysis of the implications of the Takeover Directive on corporate governance in Europe.
The Accuracy of Surgical Assessment of Gross Myometrial Invasion as a Predictor of Lymphatic Metastases in Women with Endometrial Carcinoma

Objective: The objective of this study was to determine if the surgeon can accurately predict the depth of myometrial tumor invasion in women with endometrial cancer, and if tumor invasion will correlate with node metastases. Methods: We identified 1,943 women with endometrial carcinoma who underwent hysterectomy. Of these, 295 underwent comprehensive surgical staging including lymph node analysis. All subjects also underwent gross examination of the uterine specimen by their surgeon where the depth of myometrial invasion was recorded. Patients with grade III tumors or papillary serous and clear cell histology were excluded. The presence or absence of myometrial invasion was then correlated with the incidence of nodal involvement to determine if this system can be used to predict tumor spread at the time of hysterectomy. Results: The ability of the surgeon to accurately predict the depth of myometrial invasion was 82%, sensitivity was 57%, specificity 89%, positive predictive value 62% and the negative predictive value was 88%. If this system was used as the indication for nodal evaluation the authors would have missed 3% of women with nodal metastases who had less than 50% myometrial invasion. Conclusions: Gross evaluation of the hysterectomy specimen can accurately predict depth of myometrial invasion. However, in our analysis 3% of women with less than 50% invasion had node involvement. If the surgeon had used the absence of myometrial invasion to omit nodal assessment, these lesions would have been missed. Therefore, we feel that nodal assessment should be considered in the majority of cases.
Retail Peso Exchange Rate Discounts and Premia in El Paso

This paper studies the exchange rates at which Mexican pesos are accepted for retail purchases in El Paso, Texas. A stratified random sample of 586 participating firms is surveyed to examine two aspects of reverse dollarization in the El Paso/Ciudad Juárez border region. The first is to determine the percentage of retail businesses in El Paso that accept foreign currency in the form of Mexican pesos. The results suggest that just over 13.1% (77/586) of all retail firms in this market accept pesos, which on average, comprise 4.35% of total sales for those firms. The second is to calculate the effective exchange rate at which firms accept Mexican pesos. We find that 68.5% of firms accepting the peso do so at a premium. We discern these two aspects further utilizing various multivariate analyses.
mRNA expression and protein distribution of the unspliced tenascin‐C isoform in prostatic adenocarcinoma

The inclusion or omission of the alternatively spliced region in the tenascin‐C (Tn‐C) mRNA gives rise to the large (Tn‐CL) or small (Tn‐CS) variant, respectively. Tn‐CL is thought to be a typical component of provisional extracellular matrices (ECMs) and is expressed during tumour stroma remodelling in cancer. Tn‐CL mRNA expression and protein distribution have been studied in 44 prostatic adenocarcinomas using RNA/RNA in situ hybridization supplemented by reverse transcriptase‐polymerase chain reaction (RT‐PCR), and immunohistochemistry (clone BC‐2). While the Tn‐CL protein was demonstrated within tumour stroma, Tn‐CL mRNA expression was mainly observed in carcinoma cells, regardless of the histological grade of the tumour. Carcinoma cells containing Tn‐CL mRNA were particularly localized at the tumour invasion front. Tn‐CL mRNA was also identified in benign prostatic hyperplasia, where it was present exclusively in the basal cell layer, and in prostatic intraepithelial neoplasia in which there was partial loss of positive basal cells and increasing positivity of luminal cells. Furthermore, newly formed tumour blood vessels and inflammatory and stromal cells take part in the expression of Tn‐CL and are involved in the formation of a provisional tumour matrix. It is concluded that deposits of Tn‐CL indicate rebuilding processes in non‐neoplastic as well as in neoplastic prostatic tissues. In respect of the Tn‐CL synthesis in budding prostatic carcinoma cells, the results demonstrate that tumour cells can directly produce the ECM components of carcinoma stroma, creating conditions that facilitate the process of invasion. Copyright © 2004 Pathological Society of Great Britain and Ireland. Published by John Wiley & Sons, Ltd.
A phase I study of high-dose interleukin-2 in combination with interferon-alpha 2b.

Our group and others have conducted phase II trials of high-dose interleukin-2 (IL-2) or IL-2 with the adoptive transfer of in vitro activated lymphocytes in patients with advanced malignancies. Although durable complete and partial responses were seen in patients with renal cell carcinoma and metastatic melanoma, overall response rates were low and toxicity was substantial. In preclinical models, the combination of IL-2 and interferon-alpha has synergistic antitumor activity. Based on these data, and our prior experience with high-dose IL-2 (Cetus), we conducted a trial to determine the maximum tolerated dose of IL-2 (0.4, 0.8, and 1.2 mg/m2) administered together with a fixed dose of interferon-alpha 2b (3 x 10(6) u/m2) intravenously every 8 h on days 1-5 and 15-19. Patients were monitored in the intensive care unit and given pressor support for hypotension as needed. Twenty-four patients were entered (6, 10, and 8 at each IL-2 dose, respectively; 14 renal cell carcinoma, 7 melanoma, 2 colon, and 1 hepatoma). The median age was 56 years, the male to female ratio was 19:5, and performance status was 0 or 1 (Eastern Cooperative Oncology Group) in all patients. Toxicity was similar at all dose levels, but the onset was earlier in the treatment course as the dose of IL-2 was escalated in successive cohorts; therefore, more doses were withheld at the higher dose levels. The major toxicities resulting in the interruption or stopping of treatment were hypotension requiring pressors, dyspnea, and neurotoxicity. Grade 1 or 2 fever, nausea and vomiting, fatigue, and cutaneous reactions were common at all dose levels. (ABSTRACT TRUNCATED AT 250 WORDS)
Impact of North Atlantic Teleconnection Patterns on Northern European Sea Level

Northern European sea levels show a non-stationary link to the North Atlantic Oscillation (NAO). The location of the centers of the NAO dipole, however, can be affected through the interplay with the East Atlantic (EAP) and the Scandinavian (SCAN) teleconnection patterns. Our results indicate the importance of accounting for the binary combination of the NAO with the EAP/SCAN for better understanding the non-stationary drivers inducing sea level variations along the European coasts. By combining altimetry and tide gauges, we find that anomalously high monthly sea levels along the Norwegian (North Sea) coast are predominantly governed by same positive phase NAO+/EAP+ (NAO+/SCAN+) type of atmospheric circulation, while the Newlyn and Brest tide gauges respond markedly to the opposite phase NAO−/EAP+ combination. Despite these regional differences, we find that coherent European sea level changes project onto a pattern resembling NAO+/SCAN+, which is signified by pressure anomalies over Scandinavia and southern Europe forcing winds to trace the continental slope, resulting in a pile-up of water along the European coasts through Ekman transport. We conclude that taking into consideration the interaction between these atmospheric circulation regimes is valuable and may help to understand the time-varying relationship between the NAO and European mean sea level.
Multiple recurrent atypical fibroxanthomas/superficial malignant fibrous histiocytomas of the forehead excised with Mohs micrographic surgery.

Atypical fibroxanthoma (AFX) is the most common spindle cell tumor of the skin treated with Mohs micrographic surgery (MMS). This superficial variant of malignant fibrous histiocytoma (MFH) is encountered most commonly as a solitary dermal tumor of the head and neck area. In contrast to AFX, MFH exhibits deeper histologic invasion, often occurs on the trunk and proximal extremities, and has a poorer prognosis. Recently, reports have emerged of two solitary AFXs of the ear, localized cutaneous metastases of a scalp AFX, and metastasizing AFX. We describe a patient with four AFX of the forehead, followed by a single superficial MFH 6 months after MMS. No additional recurrences were noted at an additional 6 months follow-up.
Profiling Internet Shoppers in Hong Kong

Abstract This study proposes and tests a model of Internet shopping behavior. The model postulates that consumer Internet shopping behavior is affected by consumers' demographic, psychographic, attitudinal and experiential factors. Data from 400 respondents are analyzed. Findings of this study indicate a relationship between consumers who shop online and some of the variables included in the study. Internet buyers tend to be male, well educated, with a higher income and mainly in the age bracket between 21 and 30. They are also likely to have a high Internet usage rates and other non-Internet in-home shopping experience. In addition, they tend to be time conscious, self-confident and have a more positive attitude toward Internet shopping than non-buyers have.