bluuebunny/crossref_metadata_2025_split huggingface dataset:
On The Independence Number Of Some Strong Products Of Cycle-Powers
Authors: Jurkiewicz Marcin , Kubale Marek , Ocetkiewicz Krzysztof 
Published: May 2015

Abstract
In the paper we give some theoretical and computational results on the third strong power of cycle-powers, for example, we have found the independence numbers α((C
10
2)√3) = 30 and α((C
14
4)√3) = 14. A number of optimizations have been introduced to improve the running time of our exhaustive algorithm used to establish the independence number of the third strong power of cycle-powers. Moreover, our results establish new exact values and/or lower bounds on the Shannon capacity of noisy channels.
Data Sensitive Recommendation Based On Community Detection
Authors: Su Chang , Yu Yue , Xie Xianzhong , Wang Yukun 
Published: May 2015

Abstract
Collaborative filtering is one of the most successful and widely used recommendation systems. A hybrid collaborative filtering method called data sensitive recommendation based on community detection (DSRCD) is proposed as a solution to cold start and data sparsity problems in CF. Data sensitive similarity is combined with Pearson similarity to calculate the similarity between users. α is the control parameter. A predicted rating mechanism is used to solve data sparsity problem and to obtain more accurate recommendation. Both user-user similarity and item-item similarity are considered in predicted rating mechanism. β is the control parameter. Moreover, in the constructed K-nearest neighbour set, both user-community similarity and user-user similarity are considered. The target user is either in the community or has some correlation to the community. Calculating the user-community similarity can cope with cold start problem. To calculate the recommendation, movielens data sets are used in the experiments. First, parameters α and β are tested and DSRCD is compared with traditional collaborative filtering recommendation algorithm (TCF) and Zhao’s algorithm. DSRCD always has better results than TCF. When K = 30, we have better performance results than Zhao’s algorithm.
Corporate Social Responsibility, Taxation and Aggressive Tax Planning
Authors: Knuutinen Reijo 
Published: May 2015

Abstract
Society expects companies to take into account the economic, environmental, and social effects of their operations and activities. The concept of corporate social responsibility (CSR) refers to the operations or actions of companies that are above or independent of the limits or minimum requirements set by legislation.
The economic purpose of a company and its responsibilities towards shareholders and debtors, first and foremost, is a natural starting point in reviewing the responsibilities. Also other stakeholders such as employers or public entities as tax collectors have economic requirements and expectations. Responsibility in the context of tax issues has become the topic of greater attention, with a number of stakeholder groups actively reviewing the approaches that companies take to their tax strategies and tax planning activities.
In this article CSR is reviewed especially in the context of taxation. Does CSR have any significance and importance in the context of tax law and especially income taxation? Does CSR set limits on the tax planning of companies, or is there an obligation to pay any more taxes than what has to be paid according to the law and the tax treaties? While the concept of CSR is not a legal one, neither is the approach for these questions in this article only a legal one.
Attitudes towards taxes are often contradictory. On the one hand, taxes are like any other costs for a company, but on the other hand, they are an economic contribution to the society in which the business is conducted.
The phrase “aggressive tax planning”, as opposed to regular or “acceptable” tax planning, has been used on several occasions recently. Taking a purely technical approach to tax planning is unlikely to protect companies from charges of irresponsibility and associated reputational damage. Aggressive tax planning can be characterized, for instance, by an intensive use of legal and financial tools, establishments in foreign tax havens, unbalanced capital structures and transfer prices, or a disingenuous use of tax treaties.
Still, aggressive tax planning is not a legal concept so there is no legal definition for it. Instead, the question is more or less about where to draw the line of moral acceptability, which runs on the inside of the tax planning area. From the CSR point of view, aggressive tax planning can be defined as actions taken by taxpayers which are in the line of requirements of tax law, but which do not meet the reasonable and justified expectations and requirements of the stakeholders.
Subjektafgrænsning i det fælleseuropæiske momssystem – En trist rejse fra FCE Bank til Crédit Lyonnais
Authors: Jensen Dennis Ramsdahl 
Published: May 2015

Abstract
The issue regarding output taxation, input deduction and determination of the place of taxation in VAT law is inextricably linked with a correct fact determination. This is also the case in relation to a delimitation of the individual tax subject including the question whether related subjects/units should be acknowledged as independent tax subjects, or whether they should qualify as one subject/ one unit in a legal VAT context instead. A coherent analysis of selected ECJ rulings of relevance for the delimitation of each tax subject shows that subject delimitation in national civil law also is the predominant basis in a legal VAT context unless the law contains explicit deviations from this or should be deviated from on the basis of either abuse of law or substance over form considerations. However, in this article it is proved that case C-388/11, Crédit Lyonnais breaks with this basic premise, as the ECJ in this case ignores the subject delimitation in civil law without a convincing argumentation for the fact that the law dictates this and without referring to abuse of law or substance over form.
Bastian, K. 2014. Omgørelse – Skatteforvaltningslovens § 29. 1st ed. København: Jurist- og Økonomforbundets Forlag
Authors: Pedersen Jan 
Published: May 2015

Abstract
Dansk skatteret har i årtier anerkendt, at skatteyderne - under nærmere angivne betingelser - har mulighed for såkaldt “omgørelse”. Herved har skatteyderne mulighed for at undgå en uforudset og uventet beskatning, som kunne være undgået ved at skatteyderne havde disponeret anderledes eller måske helt havde undladt at disponere. Den vigtigste form for omgørelse består af “dispositionsomgørelse”, hvorved skattemyndighederne anerkender, at parternes efterfølgende ændring af økonomiske vilkår og retligt indhold gives tilsvarende skatteretlige konsekvenser. Som eksempel kan nævnes, at skattemyndighederne med hjemmel i aktieavancebeskatningsloven tilsidesætter overdragelsessummen ved en aktiehandel mellem nært forbundne, idet afståelsessummen anses for kunstigt nedbragt. Dette indebærer en forhøjelse af overdragerens skattepligtige afståelsessum og en gavebeskatning hos erhververen af den modtagne fordel. Denne gavebeskatning kan undgås ved omgørelse, således at aktieoverdragelsen med tilbagevirkende kraft foretages til markedsværdien af aktierne. Et andet eksempel er, at en skatteyder, som efterfølgende ønsker at anvende de særlige regler for “skattefri virksomhedsomdannelse” ved omdannelse af en personligt ejet virksomhed til et selskab kan få tilladelse hertil ved en omgørelse. Virksomhedsejeren undgår herved eller får sin kapitalgevinstbeskatning reduceret.
Omgørelse er nu lovfæstet i skatteforvaltningslovens § 29, der omhandler de nærmere betingelser og fremgangsmåde.
Bogen: “Omgørelse - skatteforvaltningslovens § 29” indeholder en monografiom bestemmelsen, der indeholder en håndbog og en lærebog om omgørelse. Advokat Kaspar Bastian, som er skatteadvokat hos et af Danmarks førende advokatfirmaer, Bech-Bruun, har forfattet en monografiom såkaldt omgørelse, som den er hjemlet i skatteforvaltningslovens § 29. Omgørelse indebærer, at skattemyndighederne giver tilladelse til, at en efterfølgende ændring af eller ophævelse af en civilretlig disposition gives tilsvarende skatteretlige virkninger. Der udløses således en skattemæssig ændring med tilbagevirkende kraft. Omgørelse aktualiseres navnlig, når det konstateres, at en given aftale, disposition m.v. udløser en uventet og uforudset beskatning, som kunne have været undgået enten ved, at dispositionen fra begyndelsen af var givet et andet retligt indhold eller ved, at dispositionen slet ikke havde været gennemført.
Omgørelse indeholder således en skatteretlig “fortrydelsesregel” og sikrer navnlig mod urimelige konsekvenser af en kompleks og hastigt ændret skattelovgivning.
Kaspar Bastians bog, der både kan anvendes som håndbog for praktikeren og som lærebog på højeste akademiske niveau, omfatter 130 sider inkl. registre.
Bogen er disponeret i 6 kapitler :
Kapitel 1. Indledning, introduktion til skatteforvaltningslovens § 29, historie.
Kapitel 2. Området for omgørelse.
Kapitel 3. Betingelser for omgørelse.
Kapitel 4. Omgørelsens konsekvenser.
Kapitel 5. Formelle regler (ansøgningsprocedure, kompetenceforhold, klage m.v.).
Persson Österman, R. 2013. Förhandelsbesked i skattefrågor, 1st ed. Uppsala, Iustus Förlag Book Reviews
Authors: Kristoffersson Eleonor 
Published: May 2015

Abstract
Jag har fått uppdraget att recensera Roger Persson Östermans1 senaste verk. Redan inledningsvis vill jag framhålla att boken är välskriven och innehåller få redaktionella fel. Författaren ger klara uttryck för sin egen uppfattning, och därigenom blir boken särskilt läsvärd. Författaren är den förste sedan Sture Bergström (Förhandsbesked vid inkomsttaxering, Uppsala 1990) som tar ett större grepp om förhandsbeskedsfrågor.
Corporate income tax and the international challenge
Authors: Folkvord Benn , Jacobsen Michael Riis 
Published: May 2015

Abstract
Although globalization has contributed immensely to growth and prosperity around the world, it is a growing challenge for tax policy makers. Globalization and greater mobility of tax bases increase the relative importance of taxes in corporations’ investment decisions. The combination of highly mobile capital, inadequacies in existing tax laws and a total change of international business environment have led to the fundamental problem in international tax law labeled by the OECD as the problem of BEPS (Base Erosion and Profit Shifting), along with severe competition among countries to attract investments and business activities. These challenges are the topic for the 2014 seminar of the Nordic Tax Research Council. Based on the Nordic national reports we discuss these challenges
The international Challenges and Finnish Corporate Taxation
Authors: Lindgren Juha 
Published: May 2015

Abstract
One of the main trends in Finnish corporate taxation during the last ten years has been the lowering of the corporate tax rate. The decision to lower the corporate tax rate to 20% from the beginning of 2014 also changed the approach in reforming the corporate taxation as it was decided to stay on the grounds of a broad tax base and not to make loopholes in it with targeted exceptions.
The Finnish corporate taxation contains also some provisions that act as incentives for investment and the establishment of companies. However, the focus has been lately on the rules with purpose to protect the national tax base. Therefore, article handles both the specific anti avoidance rules and the application of the general anti avoidance rule on the cross-border transactions. Some particular challenges and the exchange of information are also taken into account before the conclusion with some ideas and aspects on future reforms.
Nasjonalrapport for Norge
Authors: Børresen Martin , Pilgaard Marius , Bjørneby Marie 
Published: May 2015

Abstract
Since the Tax Reform of 1992 Norway has had a tax system of relatively low tax rates and broad tax bases. Norway, along with other Nordic neighbours, did quite early substantially reduce its statutory corporate tax rate - reduced from 50.8 to 28 per cent as part of the 1992 Reform. After 1992 the rate has been constant at 28 until it was reduced marginally to 27 in 2014. Since 1992 the principal objective in designing the corporate tax system has been to ensure resource effectiveness. The role of the corporate (and capital) income tax is therefore to secure public revenue but at the same time minimising distortion. An important feature of the system is therefore that normal return on capital is taxed at the same rate, irrespective of whether it is earned as business income or not. The Report identifies three main challenges to the current corporate tax system. The first challenge discussed is the system’s effects on investments. It cannot be overlooked that the corporate tax rate in Norway is currently higher than the tax rate of many countries Norway is commonly compared with (e.g. other Nordic countries).
The Report suggests that this can contribute to a reduction in the level of investment in Norway.
The second identified challenge is the tax distortion between debt and equity finance. The Report briefly discusses neutrality in financing through equal tax treatment of debt and equity finance. The Report then discusses the implications and differences of an ACE and a CBIT model in this context.
The final challenge discussed is base erosion and profit shifting (BEPS). Differences in countries’ tax rules create vast opportunities for tax planning, and largely for the benefit of multinational enterprises (MNEs), inter alia through transfer pricing. The Report suggests that BEPS over time may imply a serious threat in maintaining the revenue from the corporate tax base. The Report then acknowledges that a reduction in the formal tax rate may only to some extent address the problem; which indicates a need to consider other supplementing measures. One such measure is the interest deduction limitation rule, made effective from 2014. The rule was introduced to address profit shifting in MNEs. More generally the Report recognises that Norway cannot freely introduce measures against BEPS following international obligations.
Finally the Report mentions the appointment of a Tax Commission in 2013. The Commission’s mandate is to review the Norwegian corporate tax system in light of international developments. The Commission shall deliver its report in the autumn of 2014.
The Nordea Bank Denmark Case (C-48/13)
Authors: Laursen Anders Nørgaard 
Published: May 2015

Abstract
This paper reports on an investigation of a recent decision by the European Court of Justice (ECJ) in case C-48/13, Nordea Bank Denmark, concerning the Danish rules for reincorporation of losses from permanent establishments situated in European Union/ European Economic Area (EU/EEA) member states other than Denmark. The article includes comments on various EU tax law aspects of the case - namely the restriction test applied by the ECJ, the justifications brought forward by the intervening governments and the question of proportionality - and examines the consequences of the Danish tax law going forward.
Profit ‘That is Condemned by the Word of God’: John Jewel’s Theological Method in His Opposition to Usury
Authors: Gazal André A. 
Published: May 2015

Abstract
John Jewel, regarded as the principal apologist and theologian for the Elizabethan Church, was also esteemed as one of England’s most important (if not the most important) authority on the subject of usury, and therefore was cited frequently by opponents of usury towards the end of the sixteenth century and throughout the seventeenth century. One of the most sustained interpretations of Jewel as a theologian on the subject of usury was by Christoph Jelinger, who observed that the late bishop of Sarum employed the same theological method in opposing usury as he did in defending the doctrines and practices of the Church of England against its Catholic opponents, that is, by appealing to the Scriptures, the Church Fathers, Church Councils, and the example of the primitive church. This article seeks to confirm the opinion of Jelinger, and in doing so show that Jewel’s opposition to usury stemmed primarily from the conviction that it was both a vice and heresy that eroded the unifying attribute of Christian society which was love.
Resultative and goal phrases in Polish and English: Interaction with aspect
Authors: Gulgowski Piotr 
Published: May 2015

Abstract
The article examines the interaction of resultative and goal phrases with aspect in Polish and English. The first research problem concerns the ability of resultative and goal phrases to aspectually delimit (telicize) an atelic predicate. Data from English shows that resultative and goal phrases systematically make an atelic predicate telic in non-progressive sentences, but they fail to do so in progressive constructions. In Polish, imperfective (atelic) constructions can never be aspectually delimited by such phrases. It is argued that resultative and goal phrases lose their telicizing potential when in the scope of an aspectual functional head Asp specified as [-telic]. This is the case in English progressive and Polish imperfective sentences. The Asp head is able to override the telicity specification established compositionally within VP. The Asp head in Polish is obligatory and the value of its telicity feature ([+telic] for perfective and [-telic] for imperfective) is responsible for the interpretation of the VP selected by Asp as a complement. In English such projection is optional. When it is absent, the telicity of a predicate can be computed from the default aspectual type of the lexical verb combined with other elements inside VP, including resultative and goal phrases. A related problem also addressed in the article concerns the meaning of progressive / imperfective resultative and goal constructions. The problem is presented as part of a larger task of finding a proper analysis for accomplishment predicates combined with a progressive / imperfective operator. The proposed solution is based on the notion of directionality. It is suggested that resultative and goal constructions denote a process of some entity changing in the ‘direction’ of a new state. When the process is understood as having a culmination, the ‘direction’ of the transition indicates a new state actually holding of the entity undergoing transition. When a progressive / imperfective operator is introduced, it can remove the culmination leaving just the directed-transition process. A formalization of this analysis is provided.
Diminutive affixes in the Number domain: A syntactic variation
Authors: Steriopolo Olga 
Published: May 2015

Abstract
This article investigates diminutive affixes in four unrelated languages: Maale, Walman, Kolyma Yukaghir, and Itelmen, with additional discussion of German, Breton, and Yiddish. The data show variation in the syntax of diminutives. Diminutives differ cross-linguistically in the manner and place of attachment in a syntactic tree. In terms of the manner of attachment, some diminutive affixes are shown to behave as syntactic heads, while others show a behaviour characteristic of syntactic modifiers. In terms of the place of attachment, some affixes attach in the number position, while others attach above it. This article contributes to a discussion of form-function correspondence between syntactic categories (Wiltschko, in press). It shows that although diminutives across languages have the same meaning (or function), they significantly differ in their syntactic structures (or form). Thus, there is no 1:1 correspondence between form and function of diminutives in terms of the attachment and ordering of morphemes.
Optimal scan time for evaluation of parathyroid adenoma with [18F]-fluorocholine PET/CT
Authors: Rep Sebastijan , Lezaic Luka , Kocjan Tomaz , Pfeifer Marija , Sever Mojca Jensterle , Simoncic Urban , Tomse Petra , Hocevar Marko 
Published: May 2015

Abstract

Background. Parathyroid adenomas, the most common cause of primary hyperparathyroidism, are benign tumours which autonomously produce and secrete parathyroid hormone. [18F]-fluorocholine (FCH), PET marker of cellular proliferation, was recently demonstrated to accumulate in lesions representing enlarged parathyroid tissue; however, the optimal time to perform FCH PET/CT after FCH administration is not known. The aim of this study was to determine the optimal scan time of FCH PET/CT in patients with primary hyperparathyroidism.

Patients and methods. 43 patients with primary hyperparathyroidism were enrolled in this study. A triple-phase PET/CT imaging was performed five minutes, one and two hours after the administration of FCH. Regions of interest (ROI) were placed in lesions representing enlarged parathyroid tissue and thyroid tissue. Standardized uptake value (SUVmean), retention index and lesion contrast for parathyroid and thyroid tissue were calculated.

Results. Accumulation of FCH was higher in lesions representing enlarged parathyroid tissue in comparison to the thyroid tissue with significantly higher SUVmean in the second and in the third phase (p < 0.0001). Average retention index decreased significantly between the first and the second phase and increased significantly between the second and the third phase in lesions representing enlarged parathyroid tissue and decreased significantly over all three phases in thyroid tissue (p< 0.0001). The lesion contrast of lesions representing enlarged parathyroid tissue and thyroid tissue was significantly better in the second and the third phase compared to the first phase (p < 0.05).

Conclusions. According to the results the optimal scan time of FCH PET/CT for localization of lesions representing enlarged parathyroid tissue is one hour after administration of the FCH.
The structural semiotics paradigm for marketing research: Theory, methodology, and case analysis
Authors: Oswald Laura R. 
Published: May 2015

AbstractBrands are semiotic systems that create value in the marketplace by differentiating competitors in a category, forming emotional connections with consumers, and aligning the company’s symbolic equities with contemporary cultural trends. The author aims to expand the current state of semiotics for marketing beyond advertising research to the whole gamut of media and consumer touch points in contemporary marketing, from strategic communication to retail design and consumer behavior. The importance of this paper is not limited to marketing, but raises important issues about connections heretofore ignored between semiotics, business, and the production of value in the marketplace.
Semiotics and writing systems
Authors: Proskurin Sergey G. 
Published: May 2015

AbstractThis article deals with semiotic modeling in writing. The process of modeling is involved in the creation of new scripts and alphabets. The narrative describes the so called ABC-principle in action. Since the ABC code is also a text, the letters have meaningful collocations and the letter names have meaningful associations. The sequence of letters in an ABC is a meaningful syntagm within a ritual text. We shall attempt to prove that these parts of an ABC are meaningful micro-texts that constitute a model of the world as conceived in Indo-European culture. Together with rituals, alphabets have contributed to the formation of concepts of the physical world and cultural identities.