VictorJuiz/thesis huggingface dataset:
International taxation of cross-border digital commerce
Keywords: Internet jurisdiction
E-commerce taxation
Internet governance
Jurisdiction to tax
Digital commerce taxation
Internet taxation
Nexus

This thesis discusses jurisdiction to tax cross-border digital commerce. The primary objective is to consider the reasons for the erosion of jurisdictional links, or nexus, between countries and taxpayers' digital activities and evaluate possible solutions for addressing such nexus erosion. Whilst it is argued that digital commerce is impossible to ring-fence due to digital technologies transcending all industries, the main focus of this research is on automated business models as case studies for the broader tax issues applicable across the entire digital economy. Using cloud computing, online advertising and e-tailing models as examples of digital commerce in the narrow sense, this thesis demonstrates that the proxies for establishing jurisdictional nexus have become increasingly fluid, thereby challenging the traditional international tax regimes for profits and consumption taxation. Numerous policy solutions have been proposed in order to rectify nexus erosion, including global and territorial tax models. Unlike the previous research in this area, this thesis focuses on the nexus elements of such proposals and assesses their viability in the light of the wider Internet governance jurisprudence. Global tax solutions, such as global e-commerce taxes and formulary apportionment, are analysed in the context of the international governance regime for the technical Internet infrastructure. Territorial virtual tax solutions, such as virtual permanent establishments, withholding taxes and destination cash flow taxes, are considered in the light of the Internet jurisprudence on the 'effects' and 'targeting' nexus standards. It is argued that, given the lack of technical and political infrastructure, none of the proposed routes would be viable from a practical perspective in the near future. It is concluded, therefore, that a practical solution would involve retaining the traditional profits and consumption tax models, whilst testing a narrow version of the digital targeting nexus standard as a backstop anti-abuse measure. It is envisaged that the limited anti-avoidance provision would subsequently pave the way for a comprehensive long-term solution, as digitisation continues to transform global commerce.
Durham university: last of the ancient universities and first of the new (1831-1871)
Keywords: Durham University
Nineteenth century universities

This thesis is a study of Durham University, from its inception in 1831 to the opening of the College of Physical Science in Newcastle in 1871. It considers the foundation and early years of the University in the light of local and national developments, including movements for reform in the church and higher education. The approach is holistic, with the thesis based on extensive use of archival sources, parliamentary reports, local and national newspapers, and other primary printed sources as well as a newly-created and entirely unique database of Durham students.
The argument advanced in this thesis is that the desire of the Durham authorities was to establish a modern university that would be useful to northern interests, and that their clear failure to achieve this reflected the general issues of the developing higher education sector at least as much as it did internal mismanagement. This places Durham in a different position relative to the traditional understanding of how universities and colleges developed in England and therefore broadens and deepens the quality of that narrative. In the light of the University's swift decline, and poor reputation, from the mid-1850s what were the ambitions of the founders and how did this deterioration occur? Were the critics' accusations against the University – principally that it was a theologically-dominated, inadequate imitation of Oxford, bound to the Chapter of Durham and ruled autocratically by its Warden – based on fact or prejudice? And if the critics were wrong, what were the factors that lead to the University’s failings?
Synthesis and characterisation of large area monolayer tungsten disulphide
Keywords: Tungsten Disulphide
Electroluminescence
Grain boundaries
CVD synthesis
Characterisation
2D materials
2D semiconductors
Transition metal dichalcogenides

Two-dimensional (2D) transition metal dichalcogenides (TMDs), equipped with direct bandgaps in the visible range of electromagnetic spectrum have extended the promise of 2D materials (graphene) to optoelectronics. Towards facilitating the future industrialization of 2D TMDs, this project focused on developing chemical vapour deposition (CVD) techniques for the growth of large area monolayer tungsten disulphide (WS2), which was followed by characterisations of their structural and semiconducting properties.
It was demonstrated that controlling the introduction time and the amount of sulphur (S) vapour relative to the tungsten trioxide (WO3) precursor during the CVD growth of WS2 was critical to achieving large crystal domains on the surface of silicon wafers with a 300 nm oxide layer. This improvement for CVD techniques enabled the formation of single crystalline WS2 monolayers with edges up to 370 μm which were visible to the naked eye.
Synthetic 2D materials grown by CVD are typically polycrystalline, and determining grain size within domains and continuous films is crucial for determining their structure. The thesis showed that grain boundaries (GBs) in monolayer WS2, grown by CVD, could be preferentially oxidized by controlled heating in air. Under apposite conditions, the degradation of GBs led to their clear and rapid identification using a standard optical microscope.
Subsequent studies showed that how these monolayer WS2 GBs influenced the electroluminescence (EL) behaviour in lateral source-drain devices under bias. Real time imaging of the WS2 EL detected arcing between the electrodes when probing across a GB, which then localized at the GB region as it eroded under high bias conditions. Analysis of the eroded GB region showed the formation of micro- and nanoribbons across the monolayer WS2 domains. These results provide important insights into future EL devices that utilize CVD grown monolayer TMDs when GBs are present in the active device region.
Epicardial signalling in mammalian heart regeneration
Keywords: Heart
Epicardium
Retinoic acid
Regeneration
Neonatal mice

Whilst lower vertebrate species, such as newt and zebrafish, can regenerate their hearts following substantial injury throughout life, humans and other adult mammals undergo cardiac scarring and remodelling in response to myocardial infarction (MI), which leads to chronic heart failure. However, recent work has identified a 'regenerative window' in mammals such that the 1 day-old mouse (P1) was able to regenerate lost myocardium following MI induced by ligation of the left anterior descending coronary artery (LAD) within three weeks, but an equivalent injury sustained on or after P7 resulted in adult-like wound healing. These findings suggest that developmental cues may be instructive towards regeneration.
The epicardium, the outer mesothelial lining of the heart, is an important source of cardiovascular cells and signals that respectively contribute directly to the major lineages of the forming heart and instruct muscle growth during heart development. Under normal conditions, the epicardium is quiescent in the adult heart, but is activated upon injury and can be ectopically stimulated to contribute to neovascularisation and myocardial repair in infarcted adult mouse hearts. Furthermore, organ-wide activation of the epicardium underpins zebrafish heart regeneration, functioning, in part, to contribute a vascular niche and regulate cardiomyocyte cell-cycle re-entry and proliferation. We, therefore, hypothesised that epicardial signalling may also influence heart regeneration in neonatal mice.
The aims of this project were to 1) establish the neonatal MI injury model in-house; 2) confirm and characterise neonatal mouse heart regeneration by magnetic resonance imaging (MRI) and 3) investigate the role(s) of the epicardium and epicardial signalling in mammalian heart regeneration. In addressing these aims, novel anaesthetic and aseptic protocols were designed to refine cardiothoracic surgery in neonatal mice and establish the injury model. A protocol for MRI assessment of heart regeneration in neonatal mice was also established. Consistent with previous reports, we observed significant, although incomplete myocardial regeneration after 21 days with limited anterior wall scarring when MI was induced at P1, compared to significant collagen deposition and remodelling following MI at P7. Epicardial potential was lost coincident with closure of the 'regenerative window' and the epicardial response following injury induced at regenerative (P1) and reparative (P7) time-points was documented via retinoic acid signalling as a key developmental epicardial mitogen. This work furthers our understanding of the cell and molecular mediators of regeneration in neonatal mice, and may lead to therapeutic strategies for amplifying the regenerative response of adult mammalian hearts to injury.
Developments in chiral counterion-directed asymmetric reactions
Keywords: Atropisomerism
Axial chirality
Pyrroloindolines

The research outlined herein consists of two projects, each relating to the investigation and development of asymmetric phase-transfer catalysed reactions.
The aim of the first project was to develop a two-component cascade reaction that would assemble the valuable pyrroloindoline framework from simple and readily available starting materials, namely an isocyanide-containing substrate and a Michael acceptor. Successfully, we were able to synthesise a variety of pyrroloindolines containing up to three stereocentres with excellent diastereo- and enantioselectivity.
This rapid strategy uses a chiral ammonium salt to control the selectivity and exploits the remarkable reactivity profile of acidic isocyanides. A mechanistic proposal involving hydrogen-bond activation of the isocyanide is described, originating from the specific design of the Michael acceptor component.
Meanwhile, the objective of the second project was to develop a desymmetrising SN2 reaction on achiral biaryl substrates under asymmetric phase-transfer conditions, offering a new pathway to axially chiral biaryls. We were able to generate such products, which can be subsequently derivatised, with tremendous enantioselectivity and pleasing diastereoselectivity, particularly when using a glycine Schiff base as the nucleophile.
Genomic variation in human health and disease
Keywords: quality control
RNA-seq
heritability
linear mixed models
single-cell
software
variance partitioning
genomic variation
enhancers
variant annotation
type 2 diabetes

Understanding the structure and function of genomic variation within and be- tween individuals will be crucial for the translation of genomics into improved health and clinical outcomes. This thesis addresses current issues around the study of genomic variation in that context.
Variant annotation is a vital step in the analysis of whole-genome and whole- exome sequence data. I compared variant annotations for 80 million variants from a clinically-focused whole-genome sequencing study, obtaining annotations with two different sets of transcripts and two different software tools. I found that choice of transcripts and choice of software both have a large effect on variant annotation. The extent of discrepancy in annotations has implications for all research that relies on variant annotation, especially as we try to use whole-genome sequencing in the clinic.
Type 2 diabetes (T2D) is a common, complex genetic disease imposing a large global health burden. Although over 80 genomic loci have been associated with increased risk for T2D, many questions remain about the genomic architecture of the disease. I used 11 million rare, low-frequency and common single-nucleotide variants obtained from whole-genome sequence data from 2,657 individuals with and without T2D to assess the contributions of different classes of genomic variation to T2D susceptibility. Using linear mixed model methods and variance partitioning approaches I characterised contributions from variants in different allele frequency classes. Partitioning variance into different functional classes revealed significant four-fold enrichment (P &LT; 0.01) for variants in enhancer regions identified in pancreatic islet cells and significant depletion for variants without any functional annotation (P &LT; 0.01).
Single-cell RNA-sequencing (scRNA-seq) technologies are rapidly gaining traction to interrogate transcriptomic heterogeneity across individual cells. How- ever, raw scRNA-seq data require a large amount of processing to obtain a clean, tidy dataset ready for statistical modeling. I have developed a new, self- contained R software package, SCATER, to fill the niche between raw scRNA-seq data and downstream analysis. The package streamlines the pre-processing, quality control and data normalisation procedures while enabling flexible ways to visualise data and integration with other scRNA-seq analysis tools.
The expression patterns of non-classical and classical forms of HLA-B27 in spondyloarthritis
Keywords: non-classical HLA-B27
Ankylosing Spondylitis
B27 transgenic rat model

The strong association of the human leukocyte antigen HLA-B27 (B27), with spondyloarthropathies (SpA), was discovered more than four decades ago, yet the role B27 plays in disease pathogenesis remains unclear. It has been demonstrated that HLA-B27 can form non-classical FHC forms, including B27 FHC homodimers (B272) and misfolded FHCs. Two leading theories of SpA pathogenesis proposed that both cell surface NC-B27 (the B27 homodimer theory) and intracellular (the B27 misfolding and UPR theory) can drive immune responses in SpA. Several studies demonstrated that cell surface NC-B27 binds to immune receptors and suggested that these interactions can activate Th17 immunity. My DPhil project focuses on the investigation of the cell surface expression of NC-B27 molecules in cells and tissues obtained from AS patients and B27 TG2 rats. I used both existing reagents and a novel HD6 antibody, generated against B272, to examine the expression of HLA-B27 by flow cytometry, confocal microscopy and immunoprecipitation. This thesis provides evidence that the expression of HD6- and HC10-reactive molecules in AS patients is rather restricted to specific cell types (e.g. osteoclasts) and possibly particular environmental factors and tissue types (e.g. synovial fluid and joint tissue). My data using B27 TG2 rats demonstrated that resident joint cells express HD6- and HC10-reactive molecules before the onset of clinical manifestations. Furthermore, I showed increased expression of NC-B27 on antigen presenting cells (APCs), and CD161+ and CD8+ cell populations in blood and secondary lymphoid organs. Based on these findings I hypothesized that cell surface expression of NC-B27 may not only be crucial for activation of Th17-driven immune responses, but may also shift the balance between immune tolerance and activation. Importantly, the expression of potentially pathogenic HD6-reactive molecules is restricted to specific cell and tissue types hence HD6 antibody may be a potential future therapeutic agent in SpA.
3D printing in the commons: knowledge and the nature of digital and physical resources
Keywords: Open source
Resources

3D printers are a type of digital fabrication tool being used by communities committed to shared software, hardware, and digital designs. This shared digital knowledge can be understood as an emerging common resource for the fabrication of physical goods and services. Yet the knowledge associated with physical resources used in 3D printing is less understood. This thesis explores what factors enable or prevent knowledge about physical materials entering the commons.
3D printing, with its particular configuration of digital and physical goods, offers a unique angle to advance the field of commons scholarship. This thesis elaborates the use of commons theory for traversing the boundary between knowledge associated with physical materials and digital content from the perspective of 3D printer users. Particular contributions are made to the branch of knowledge commons theory: notably, how design rules in technological systems can be used to theorise boundaries; how differentiating between the nature of underlying resources can help explain the inclusion of knowledge in the commons; and, how patterns of user engagement with types of knowledge in the commons can be studied over time.
To develop these contributions I employ theory on the design rules of technological architecture, and use insights from the study of peer production in online communities. Empirical data comes from a qualitative study of users of Fab Labs, community workshops for digital fabrication, as well as from a quantitative study of the online user forum for the Ultimaker 3D printer.
Advance relief in aircraft finance and the Cape Town Convention
Keywords: Aircraft Protocol
Cape Town Convention
Relief Pending Final Determination

The Cape Town Convention came into force on the 1st April 2004 and the Aircraft Protocol came into force on 1st March 2006. To date, the Convention has sixty-six States Parties, the Aircraft Protocol fifty-eight States Parties, and together they can be regarded as one of the most successful recent commercial law treaties. The Convention's overriding object is to offer creditors the highest possible protection in the form of an effective, speedy and strong legal remedial framework for the international enforcement of creditors rights in the event of the debtor's default or insolvency. The underlying rationale is that this will lead to significant reductions in borrowings costs for lenders to the advantage of all interested stakeholders in the aircraft sector. However, without effective implementation of the remedial system of the Convention and the Aircraft Protocol, it is difficult for financiers to have confidence that they are able to defend their legal rights effectively.
First, this thesis examines the legal nature and purpose of Article 13 ("Relief Pending Final Determination") of the Cape Town Convention, since it does not fit any traditional remedy under domestic law. Secondly, this thesis answers the crucial questions whether, and to what extent, elements of national procedural law in a Contracting State are relevant to the application of advance relief under the Convention. Further, to the extent that domestic procedural law may be applicable, the thesis examines if the relevant domestic rules of procedure are in conformity with the fundamental principles of the Cape Town Convention and the legal nature of advance relief. Ultimately, it thereby clarifies the relationship between the Convention and national procedural law in the context of Article 13.
Past, present and future volcanic activity at restless calderas in the Main Ethiopian Rift
Keywords: Volcanology

There is growing recognition that magma plays a key role in the extension and eventual break-up of the continental lithosphere. One of the most intriguing aspects of magmatism during the transition from continental rifting to sea-floor spreading is that large silicic magmatic systems develop within the rift zone. However, the processes by which these silicic magmatic centres develop as well as their larger role in rift development remains poorly understood.
This thesis focuses on silicic volcanism in the Main Ethiopian Rift; the most extensive active continental volcanic field in the world, and home to over 10 million people. I use a variety of geological, geochemical, geophysical and geochronological techniques to explore spatial and temporal variability in volcanism in this active rift segment. In particular I focus on Aluto volcano, a restless caldera volcano just &Tilde; 200 km south of Addis Ababa, but by extension I make inferences about what this means for past, present and future volcanism at other caldera systems in East Africa.
Aluto has been active for over 300,000 years, and has overwhelming erupted chemically-evolved peralkaline rhyolites that are derived through protracted (>80%) fractional crystallisation. Tectonic faults dissect the volcanic complex, and along with an underlying caldera ring fault provide key pathways for fluid release. Episodic ground deformation events occur at Aluto, and are characteristic of a coupled magmatic-hydrothermal system, where faults networks connecting the surface and deep reservoirs play an important role in the deflation. Finally, new 40Ar/39Ar geochronology suggest that silicic volcanism in this segment of the rift is pulsed, not steady, on human evolutionary timescales.
Carbon dioxide and coccolithophore physiology in ancient oceans
Keywords: Proxies
Coccolithophores
Coccoliths
Carbon Dioxide
CO2
Carbon isotopes
Fossils
Paleoclimate
Calcification

Coccolithophores form an important and dynamically evolving component of the carbon cycle. These ubiquitous single-celled marine calcifying phytoplankton are re- sponsible for half of the calcium carbonate production in the modern surface ocean, and their adorning calcite plates (coccoliths), produced intracellularly, have con- tributed to sedimentary carbonate for over 200 million years. They constitute a significant control on the partitioning of carbon between the atmosphere, ocean and sedimentary reservoirs on timescales from the instantaneous to the geological. Coc- colithophores are also uniquely placed to record aspects of the carbonate chemistry of the surface ocean, because the carbon isotopic composition of the organic matter (δ13Corg) and calcite (δ13Ccal) that they produce is a function of many parameters, including ambient aqueous carbon dioxide concentration [CO2].
This thesis addresses the bidirectional interaction between coccolithophores and the carbon cycle in the geological past, by asking how cellular carbon fluxes relate to physical evidence that is preserved throughout geological time. First, I present and calibrate a novel rationale for size-normalising coccolith mass, and show that over two glacial-interglacial cycles, coccolithophores appear to calcify more under high [CO2] conditions; a result that is manifest on evolutionary timescales, and is necessarily elusive to experiments. Second, I investigate the parameters controlling δ13Ccal and δ13Corg in coccolithophores through in vivo experimentation, and devel- opment of a model of cellular isotopic fluxes. I show that so called "vital effects" in coccolithophores arise as a result of differences in calcification to photosynthesis ratios. Third, using a combination of novel and established protocols for extraction and isotopic analysis of specific organic molecules from fossils taxonomically separated by size, I show the very first size-specific geologic time series of coccolith-associated δ13Corg, and the first time-series of size-separated coccolith δ13Ccal over a glacial cycle. A novel means of inferring past carbon dioxide concentrations, based on an iterative inverse modelling approach, is presented and tested.