VictorJuiz/thesis huggingface dataset:
Reformulating corporate residence: a coherent response to international tax avoidance

This thesis analyzes the concept of corporate residence, with particular reference to the law in the UK and Canada. It explores why corporate residence is relevant in tax policy, how corporate residence is understood in law, and how revenue authorities respond to the use and alleged 'abuse' of residence rules. Part I argues that the residence of taxpayers generally (individual or corporate) remains a relevant factor in international tax design, that taxation of corporations on the basis of residence has some justification, but that there is a disjunction between meaningful residence-based taxation and current definitions of corporate residence in domestic law and tax treaties. The formulations of residence based on incorporation, central management and control, and place of effective management, particularly as applied to multinational enterprises, are considered and are found to be deficient. Part II critically analyzes the major policy responses of the UK and Canadian governments to the exploitation of corporate residence. It argues that key legislative and administrative responses to international tax avoidance activities, for both outbound and inbound investment, are purportedly based on the acceptance of formal corporate residence yet undermine that concept in an effort to impose tax or refuse treaty relief based on where economic interests actually exist. The responses considered are the application of controlled foreign companies legislation to offshore subsidiaries, the invocation of treaty anti-abuse rules with respect to offshore intermediaries, and the use of overarching general anti-avoidance measures to challenge varied structures that rely on offshore entities. These haphazard anti-avoidance rules are overlaid with revenue authorities' indignation at the motivations that underlie many corporate relocations. It is argued that a more coherent approach would be to focus on the objective reality or unreality of corporate establishment, by reformulating corporate residence in domestic law and tax treaties.

Keywords: tax planning
resident
companies
corporations
tax avoidance
residence
multinational enterprises
Advisor: Freedman, J
First-principles investigation of electron-phonon interactions in novel superconductors

Despite over 100 years of scientific research, a full understanding of superconductivity remains elusive. While it is known that the electron-phonon interaction is responsible for the formation of Cooper pairs in conventional superconductors, many superconductors exhibit behaviour suggestive of more exotic pairing mechanisms.
In this thesis, two novel superconducting materials are considered, monolayer transition metal dichalcogenide, MoS2, and iron-based superconductor, LaFeAsO1−xFx. The former is ideal for the study of the electron-phonon interaction, as it not only has potential applications as an atomically thin transistor, but also displays a dome-shaped superconductive state as a function of electron doping. In the latter, the superconductive state emerges from a magnetic parent compound upon flourine doping. Its high critical temperature is thought to be enhanced by magnetic fluctuation rather than being purely phonon-mediated.
By using novel first-principles techniques, the electron-phonon interaction in electron doped single-layer MoS2 is investigated. The superconducting gap is calculated using the Migdal-Eliashberg theory, and by considering the electronic structure and lattice dynamics in this material, an explanation is provided for the experimentally observed doping-dependent critical temperature in this material.
The origin of the doping-induced transition from a magnetic phase to a nonmagnetic phase in LaFeAsO1−xFx is determined. A new model to capture the effects of the fluorine dopants is developed, which has implications for the electron-phonon interaction in this material.

Keywords: Density functional theory
Electron-phonon
Superconductivity
Advisor: Giustino, F
Phagocytosis of antigens by Langerhans cells

Mature dendritic cells (DC) isolated from lymphoid tissues initiate antigen-specific T-dependent responses even though they are non-phagocytic and weakly pinocytic, whereas Langerhans cells (LC; immature DC) can process protein antigens but are poorly immunostimulatory. Thus antigens may be acquired by cells of this lineage at an immature stage but, to our knowledge, there have been no studies on the phagocytic capacity of these cells in vitro.
Using a newly-developed flow cytometric assay to measure the association between fluorescent markers and LC in epidermal cell cultures, and light and electron microscopy, we have observed phagocytosis of a variety of particles by freshly-isolated LC. The cells readily phagocytosed zymosan, heat-killed S. cerevisiae, bacteria (S. aureus and C. parvum) and fluorescent latex beads, but were unable to take up IgG- or complement-coated sheep erythrocytes, as opposed to MØ. Similarly, many freshly-isolated splenic DC had some phagocytic activity. However, the capacity of both LC and splenic DC to phagocytose zymosan, bacteria and fluorescent latex beads was markedly decreased after maturation in culture, consistently with the fact that mature DC are poorly phagocytic.
Zymosan binding and uptake were much greater in fresh LC from C57BL/6 compared to BALB/c mice, and the loss of phagocytic capacity for zymosan during maturation followed different kinetics in the two strains. Two receptors mediating uptake of zymosan in LC were identified based on the effect of different inhibitors. Both of these receptors, recognising mannose and β-glucan residues, appear to be differentially regulated in the two mouse strains and during culture of LC.
Our findings support the notion that DC are capable of acquiring particulate antigens for presentation at an immature stage, through recognition units for carbohydrate determinants common to a variety of potentially pathogenic organisms.

Advisor: Austyn, J
A cascade approach towards the gephyrotoxins

The aim of this project was to develop a cascade approach towards perhydropyrrolo-[1,2-a]-quinolines and to apply this to the asymmetric synthesis of the gephyrotoxin alkoids.
Chapters Two and Three outline the development of a synthetic route towards a range of cascade precursors, whilst Chapter Four outlines investigations into the enamine-Michael cascade. Central to understanding the cascade process was the discovery that the major product of the enamine-Michael cascade was the unusual tricyclic hydroquinium salt. This can subsequently be engaged in a diastereoselective inter- or intramolecular reduction to afford either a trans-perhydro-[1,2-a]-quinoline or a tetracyclic aminal in high overall yield depending on the C1 oxygen substituent.

Keywords: natural product synthesis
organic chemistry
Advisor: Smith, M
The politics of land in Tanzania

This is a study of the politics of public policy. It provides analysis of land policy and a study of policy making and of the Tanzanian state. Rather than deducing the state's agenda from its actions and the policies it produces, this thesis seeks to examine the interactions between the significant factions and personae of the Tanzanian political and administrative elites. This approach goes beyond identifying the divisions within the state between the Party leadership, the technocrats within the Government, and the Presidency. The thesis demonstrates how the ways in which conflicts are resolved, or deferred, and compromises are reached can lead to outcomes which do not necessarily constitute the sum of identifiable interests. In particular, a 'hidden level of government' is uncovered which consists of a technocratic elite which has, to a large extent, managed to depoliticise otherwise sensitive and controversial policy decisions and thus impose their stamp on policy outcomes.
This approach to the analysis of rural land policies reveals the continuities in the state's approach to land issues. Since the colonial period, the objective of Tanzania's land policies has been to transform the countryside from the presumed inefficiencies of the 'traditional' modes of land use to fit the needs of a 'modern' and monetised economy. The modernising policies have provided the rationale for an authoritarian approach to land tenure and have been implemented by a centralised land administration. This thesis' historical analysis of the policies associated with the period of ujamaa and villagisation, and of the case studies of the 1983 Agricultural Policy and the 1995 National Land Policy, show that a modernising discourse and centralising administrative practices have remained at the centre of the policy agenda, despite dramatic changes in economic strategies and political institutions, and controversies over the future direction of land policies. The resulting land tenure regime relies on discretionary decision making by politicians and land officials and fails to provide workable procedures of checks and controls against malpractice. This study's detailed examination of the formulation of the National Land Policy reveals how a small elite of senior civil servants were able to hijack the policy making process and side-step political pressure for reform. They ignored, or appropriated selectively, the evidence and recommendations produced by comprehensive policy reviews, including the 1992 Presidential Commission of Inquiry, to maintain their direction of land policy while failing to address the evident shortcomings of the existing land policy regime.
Compositional distributional semantics with compact closed categories and Frobenius algebras

The provision of compositionality in distributional models of meaning, where a word is represented as a vector of co-occurrence counts with every other word in the vocabulary, offers a solution to the fact that no text corpus, regardless of its size, is capable of providing reliable co-occurrence statistics for anything but very short text constituents. The purpose of a compositional distributional model is to provide a function that composes the vectors for the words within a sentence, in order to create a vectorial representation that re ects its meaning. Using the abstract mathematical framework of category theory, Coecke, Sadrzadeh and Clark showed that this function can directly depend on the grammatical structure of the sentence, providing an elegant mathematical counterpart of the formal semantics view. The framework is general and compositional but stays abstract to a large extent.
This thesis contributes to ongoing research related to the above categorical model in three ways: Firstly, I propose a concrete instantiation of the abstract framework based on Frobenius algebras (joint work with Sadrzadeh). The theory improves shortcomings of previous proposals, extends the coverage of the language, and is supported by experimental work that improves existing results. The proposed framework describes a new class of compositional models thatfind intuitive interpretations for a number of linguistic phenomena.
Secondly, I propose and evaluate in practice a new compositional methodology which explicitly deals with the different levels of lexical ambiguity (joint work with Pulman). A concrete algorithm is presented, based on the separation of vector disambiguation from composition in an explicit prior step. Extensive experimental work shows that the proposed methodology indeed results in more accurate composite representations for the framework of Coecke et al. in particular and every other class of compositional models in general.
As a last contribution, I formalize the explicit treatment of lexical ambiguity in the context of the categorical framework by resorting to categorical quantum mechanics (joint work with Coecke). In the proposed extension, the concept of a distributional vector is replaced with that of a density matrix, which compactly represents a probability distribution over the potential different meanings of the specific word. Composition takes the form of quantum measurements, leading to interesting analogies between quantum physics and linguistics.

Keywords: distributional models
computational linguistics
compositionality
category theory
vector space models
mathematics of language
categorical quantum mechanics
semantics
Advisor: Sadrzadeh, M
Coecke, B
Pulman, S
Electronic structure of open-shell transition metal complexes

This thesis presents electronic structure calculations on problems related to the bonding in inorganic coordination compounds and clusters. A wide range of molecules with the ability to exist in different structural forms or electronic states has been selected and density functional theory is systematically applied in order to gain detailed insight into their characteristics and reactivity at the electronic level. First, we address the question of redox non-innocent behaviour of bipyridine in a series of 1st row transition metal complexes. Complexes of the type [M(2,2'-bipyridine)(mes)₂]0 (M = Cr, Mn, Fe, Co, Ni; mes = 2,4,6-Me₃C6H₂) and their one-electron reduced forms have been explored. The results clearly show that the anions are best described as complexes of the monoanionic bipyridine radical (Sbpy = 1/2), giving a rationale for the observed structural changes within the ligand. Likewise, we have identified dianionic bipyridine in both the complexes [Zn2(4,4'-bpy)(mes)₄]²− and [Fe(2,2'-bpy)₂]²−. In no case have we found evidence for significant metal-to-ligand backbonding. The subject of redox-noninnocence is further revisited in a comparative study of the two complexes [M(o-Clpap)₃] (M = Cr, Mo; o-Clpap = 2-[(2-chloro-phenyl)azo]-pyridine), and their associated electron transfer series. The results indicate that all electron transfer processes are primarily ligand-based, although in the case of the Mo analogue these are coupled to substantial electron density changes at the metal. The ability of pap to form radical anions finds a contrasting case in the di- nuclear Rh complex [Rh₂(μ-p-Clpap)₂ (cod)Cl₂], where the two ligand bridges act as acceptors of strong dπ∗ backbonding from a formally Rh–I centre. We then direct our attention to the endohedral Zintl clusters [Fe@Ge10]³− and [Mn@Pb12]³−, which reveal peculiar topologies. We have probed the electronic factors that influence their geometric preferences, and propose a model based on the shift of electron density from the endo- hedral metal to the cage to account for the observed geometries. Subsequently, we reassess the electronic structure of the xenophilic clusters Mn₂(thf)₄(Fe(CO)₄)₂ and [Mn(Mn(thf)₂)₃(Mn(CO)₄)₃]–. We conclude that these are best viewed as exchange coupled MnII centres bridged by closed- shell carbonylate fragments. In the closing chapter the reduction of NO₂– to NO by the complex [Cu(tct)(NO₂)]+ (tct = cis,cis-1,3,5-tris(cinnamylideneamino)cyclohexane) is studied, a process that mimics the enzyme-catalysed reaction. Two viable pathways for the reaction have been traced and key inter-mediates identified. Both direct release of NO or via decomposition of a Cu-NO complex are kinetically and thermodynamically feasible.

Keywords: Zintl ions
redox non-innocence
xenophilic metal clusters
CuNiR
broken-symmetry
MO theory
DFT
Advisor: McGrady, J
Structural studies on determinants of receptor/ligand binding in the tumour necrosis factor and T cell receptor protein families

Protein-protein recognition plays a central role in the surveillance of self and non-self in the mammalian immune system and ultimately in cellular survival within the organism. Two systems of fundamental importance to the immune system are the Tumour Necrosis Factor (TNF) and the T cell receptor (TCR) families.
High-throughput methods developed within the Oxford Protein Production Facility have been successfully applied to the production of members of the TNF receptor and ligand superfamilies for structural characterisation. The TNF receptor DR6 was successfully refolded from E.coli inclusion bodies using a rapid-dilution technique and yielded diffraction quality crystals. Data collected from these crystals will be used to obtain an x-ray crystallographic model of DR6. Vascular Endothelial Growth Inhibitor (VEGI) was produced as a soluble recombinant protein in E.coli, and formed a number of poorly diffracting crystals, it is hoped that further trials and optimization of conditions will lead to improved data quality. Lymphotoxin β receptor was produced in a Eukaryotic system. This has shed light on the complications posed by signal peptide cleavage and glycosylation on the production of protein for crystallization trials.
TNF superfamily proteins are ideal targets for the design of novel therapeutic agents due to their involvement in a number of disease pathologies. Various methods of molecular docking and small molecule design were applied to the search for potential inhibitors of receptor binding for the TNF ligand proteins TRAIL and BAFF. A number of potential drug leads were identified from the National Cancer Institute drug database.
The Natural Killer (NK) T cell restricted TCRs recognise CD1d-presented glycolipid. Determination of the crystal structures of the invariant NK TCR and the NK restricted TCRs 5E and 5B shows that these proteins adopt the canonical structures of class I MHC restricted TCRs. This suggests that the binding of CD1d-glycolipid by these receptors will conform to the same model of binding seen for the class I MHC restricted TCRs.

Keywords: T-Cell Receptor
X-ray crystallography
TNF
Advisor: Jones, E
An autonomy-based foundation for legal protection against discrimination

The impressive growth of antidiscrimination law in liberal democracies in the past few decades belies the inadequacy of the normative bases on which it has been sought to be justified. Popular ideals such as rationality, equality and dignity have been unsuccessful in providing a coherent liberal framework for the fundamental aspects of the practice of antidiscrimination law. In this thesis, I have argued that a unified normative framework comprising autonomy and dignity-as-autonomy does a markedly better job of justifying the most fundamental aspects of these laws. The ideal of personal autonomy is understood here as a principle that seeks to guarantee an adequate range of valuable options to individuals. Dignity-as-autonomy is understood to be an expressive norm, which forbids certain persons from expressing contempt for the autonomy of another. These ideals have different forms: autonomy is a non-action-regarding principle, while dignity-as-autonomy is action-regarding. They are also distinct substantively: it is often possible to violate one of them without affecting the other. When these ideals make incompatible demands, I argue that those made by autonomy should prevail. Mandating positive action and reasonable accommodation on the one hand, and prohibiting indirect discrimination and harassment on the other, are essential features of a model of antidiscrimination law based on this framework. Further, under this framework, antidiscrimination law is not vulnerable to objections such as ‘levelling down’ and responds well to claims of discrimination on ‘intersectional grounds’. Furthermore, it is not essential to find an ‘appropriate comparator’ in order to prove discrimination. This model also explains when, and under what conditions, can some forms of discrimination be ‘justified’. Finally, on an autonomy-based model, antidiscrimination law is only one of several complementary tools that should be employed to protect and promote personal autonomy.

Keywords: antidiscrimination
equality
discrimination
autonomy
dignity
Expressive theory
Advisor: Bamforth, N
NMR spectroscopic measurements of diffusion in heart

A decrease in the apparent diffusion coefficient (ADC) of water is becoming an important tool for the detection of acute and chronic brain disorders, yet it is not known whether changes in myocardial ADCs hold similar potential. Consequently, this work determined whether the ADCs of water or intracellular metabolites could be used to show ischaemia or cell swelling in the isolated rat heart.
A modified STEAM pulse sequence was designed to measure the ADCs of the 1H-NMR detectable metabolites, taurine and creatine, with 4 min time resolution in a 3 mm myocardial slice. Experiments included the measurement of: a) metabolite diffusion coefficients and diffusion tensors in solutions, and ADCs and diffusion tensors in the isolated, KCl-arrested rat heart; b) taurine and creatine content during 32 min total, global ischaemia in the isolated rat heart; c) metabolite and water ADCs before, during and after ischaemia; and d) changes in average cardiomyocyte diameter during perfusion and ischaemia using the taurine ADC measurements.
At a diffusion time of 50 ms, the myocardial ADCs were 1.06 x 10-3 mm2/s for water, 0.29 x 10-3 mm2/s for taurine and 0.26 x 10"3 mm 2 /s for creatine. Neither taurine nor creatine was lost from the heart during ischaemia, making either suitable for ischaemic diffusion measurements. Contrary to changes in the brain, myocardial water and taurine ADCs remained constant during ischaemia; however, the total creatine ADC increased by 35% which was shown to result from hydrolysis of PCr to creatine. Using the taurine ADC measurements at diffusion times between 50 ms and 1510 ms, the average myocyte diameter was calculated to be 40 μm during perfusion and 27 μm by the end of ischaemia. The decrease in myocyte diameter indicates that the buffer perfused heart is highly oedematous. This is the first time that: 1) metabolite ADCs have been measured in isolated heart, and 2) NMR spectroscopy has been used to determine the myocyte diameter. Thus ADC changes may not have potential for detecting ischaemia in the heart, although the measurement of myocyte diameter using taurine ADCs could indicate myocardial oedema.
Studies on optical characterisation of carbon nanotube suspensions

This thesis reports studies done on single-walled carbon nanotubes (SWNTs) using optical spectroscopy as the primary investigative technique. It focuses on advances in sample preparation which have been made possible through improvements to the method of photo-luminescence excitation (PLE) mapping of nanotubes.
An introduction to the field and some theoretical models are presented initially to provide a background to the experimental chapters which follow. A description of the standard procedure for sample preparation in aqueous surfactants is then followed by a detailed introduction to PLE mapping, including modeling of SWNT spectra. The next chapter discusses improvements to the sample preparation method by using organic polymer solutions instead of aqueous surfactants for suspending the nanotubes. The results show reductions in the distribution of SWNT species which are solubilised, leading to significant improvements in the resolution of the optical absorbance spectra and an increased photoluminescence yield.
Two experiments which were performed on the novel polymer-SWNT systems are then described. The first shows (via PLE mapping) that energy is transfered to the SWNTs when the polymer is photo-excited. The possible mechanisms behind this, as well as the implications for using carbon nanotubes as an additive in polymer photovoltaics, are discussed. The second experiment details a recent magneto-PL study of SWNTs embedded in films produced from the polymer solutions. Here, the improved optical signatures and absence of strain at low temperatures have revealed a previously unseen high field intensity dependence. The behavior has been explained by the magnetic field induced mixing of the excitonic states.

Keywords: excitons
carbon nanotubes
photoluminescence spectroscopy
Advisor: Nicholas, R